BROWN v. CLAIMS MANAGEMENT RESOURCES INC.
2017 OK 13
| Okla. | 2017Background
- Rodney Brown, a claims adjuster for Claims Management Resources (CMR), injured his left knee on March 25, 2014 while descending an interior stairwell after clocking out.
- Brown worked on the building's second floor; CMR occupied the entire second floor and evidence supported CMR's ownership of the building and stairwell. Other tenants used the stairwell.
- Brown had clocked out and was exiting the premises via the stairwell (he testified he used stairs due to an employer wellness program; an elevator was available).
- CMR conceded the injury occurred but denied compensability under 85A O.S. Supp. 2013 § 2(13)(c) (exclusion for injuries in parking lots or common areas adjacent to employer's place of business before/after work) and § 2(9)(b)(3) (injury when employment services were not being performed).
- The ALJ and Workers' Compensation Commission denied benefits; the Court of Civil Appeals affirmed. The Oklahoma Supreme Court granted certiorari.
Issues
| Issue | Brown's Argument | CMR's Argument | Held |
|---|---|---|---|
| Whether injury occurred "in the course and scope of employment" under §2(13) | Ingress/egress is integral to employment; stairwell was on employer's premises so exception for "parking lot or other common area adjacent" doesn't apply | Injury occurred in a common area after clocking out and is excluded by §2(13)(c) | Reversed: stairwell was on employer's premises; exception in §2(13)(c) applies only to areas adjacent to (off) the premises and only after employee leaves premises, so Brown was within course and scope |
| Whether injury is a "compensable injury" under §2(9) | Clocking out did not end "employment services" because Brown was performing employer-directed duties (exit the workstation/use premises); thus injury arose out of course/scope of employment | Injury occurred after Brown stopped performing employment services and thus excluded by §2(9)(b)(3) | Reversed: "employment services" at least includes required duties such as complying with employer instructions to leave workstation and premises; Brown was performing employment services when injured, so injury is compensable |
| Whether "employment services" equals "course and scope of employment" | Seeks broad reading equating the terms to capture ingress/egress | Argues narrower reading excludes post-clock-out injuries | Court: terms related but distinct; statutory structure shows "employment services" may include duties necessary to employment (e.g., required ingress/egress) without wholly equating the phrases |
| Constitutional challenges to the statutory exclusions | Argued AWCA exclusions denied adequate remedy and violated due process | Defendants defended statute as valid legislative reform of remedies | Court declined to address constitutional claims because statutory interpretation resolved the case on non-constitutional grounds |
Key Cases Cited
- Bober v. Oklahoma State Univ., 378 P.3d 562 (Okla. 2016) (interpreting §2(13)(c) and holding the "adjacent" exception does not apply while employee remains on employer premises)
- Lee v. Bueno, 381 P.3d 736 (Okla. 2016) (statutory construction and review standards for questions of law)
- Wylie v. Chesser, 173 P.3d 64 (Okla. 2007) (statutory interpretation rules; legislative intent governs plain language)
- Okla. Dept. of Pub. Safety v. McCrady, 176 P.3d 1194 (Okla. 2007) (standard for affirming administrative factual findings where supported by substantial evidence)
- Jivan v. Economy Inn & Suites, 260 S.W.3d 281 (Ark. 2007) (Arkansas court equating tests for "employment services" and course of employment under a similar statutory exclusion)