BROWN v. CLAIMS MANAGEMENT RESOURCES INC.
2017 OK 13
| Okla. | 2017Background
- Rodney Brown, a claims adjuster for Claims Management Resources (CMR), fell down an interior stairwell in CMR's building after clocking out on March 25, 2014 and injured his knee.
- CMR occupied the entire second floor (Brown's workspace) of the building; other tenants had access to the stairwell; CMR encouraged stair use via a wellness program but did not require it.
- Brown could not identify a cause for the fall; he used stairs rather than the elevator because of the wellness program.
- CMR denied compensability under the Administrative Workers' Compensation Act (AWCA), arguing 1) the injury was excluded by the course-and-scope exception for injuries in a parking lot or other common area adjacent to the employer’s place of business after clocking out (85A O.S. Supp. 2013 § 2(13)(c)), and 2) the injury occurred when “employment services” were not being performed (85A O.S. Supp. 2013 § 2(9)(b)(3)).
- The ALJ and Workers’ Compensation Commission denied benefits; the Court of Civil Appeals affirmed. The Oklahoma Supreme Court granted certiorari.
- The Supreme Court reversed, holding Brown was on the employer’s premises and performing employment services when injured, so his injury was within course and scope and compensable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether injury was within "course and scope of employment" (85A §2(13)) | Brown: ingress/egress to workstation is integral to employment; stairwell was on employer premises so §2(13)(c) (adjacent common-area exception) does not apply | CMR: fall occurred after clocking out in a common area adjacent to employer’s place of business, so exclusion applies | Held: Stairwell was on employer premises (CMR-owned building); §2(13)(c) exception applies only to areas adjacent to premises; Brown was still on premises and thus in course and scope of employment. |
| Whether injury is a "compensable injury" (85A §2(9)) | Brown: injury arose out of and in the course and scope of employment; "employment services" includes required tasks such as clocking out and exiting workstation | CMR: excluded by §2(9)(b)(3) because injury occurred when employment services were not being performed (after clocking out) | Held: "Employment services" includes required actions incidental to the job (e.g., clocking out and exiting the workstation on premises); Brown was performing employment services when injured, so injury is compensable. |
| Whether statutory language is ambiguous and subject to strict construction | Brown: statutory exclusions should not defeat compensability for ingress/egress | CMR: plain text excludes injuries after clock-out in adjacent common areas | Held: Court applied statutory interpretation rules and prior precedent (Bober) — statute construed to give effect to each provision; not equating "employment services" exactly with "course and scope," but interpreting "employment services" to include required duties such as exiting workstation on premises. |
| Constitutional challenges to AWCA exclusions | Brown: statutes leave him without adequate remedy; due process violations | CMR: challenged statutes valid | Held: Court avoided constitutional ruling because Brown prevailed on statutory grounds; constitutional questions not reached. |
Key Cases Cited
- Bober v. Oklahoma State University, 378 P.3d 562 (Okla. 2016) (interpreting §2(13)(c) and holding exception applies only when employee has left the employer's premises)
- Lee v. Bueno, 381 P.3d 736 (Okla. 2016) (statutory construction and de novo review for legal questions)
- Oklahoma Department of Public Safety v. McCrady, 176 P.3d 1194 (Okla. 2007) (substantial-evidence standard for agency factual findings)
- Wylie v. Chesser, 173 P.3d 64 (Okla. 2007) (rules of statutory interpretation)
- Jivan v. Economy Inn & Suites, 260 S.W.3d 281 (Ark. 2007) (discussed as analogous treatment of "employment services" in a statute with a similar exclusion)