CARLOCK v. WORKERS' COMPENSATION COMMISSION
2014 OK 29
| Okla. | 2014Background
- Multiple petitioners sought the Oklahoma Supreme Court’s original jurisdiction to resolve disputes about post‑2013 changes to the workers’ compensation adjudicative structure (Laws 2013, SB 1062).
- The statutory change dissolved the Workers’ Compensation Court and created the Court of Existing Claims for pre‑February 1, 2014 injuries and other new structures effective February 1, 2014.
- Petitioners challenged whether orders and awards by the Court of Existing Claims for injuries occurring before February 1, 2014, can be reviewed by the Workers’ Compensation Commission under 85A O.S.Supp.2013, § 400.
- Petitioners also sought guidance about how vacancies on the Court of Existing Claims are to be filled.
- The Supreme Court granted original jurisdiction to resolve the declaratory question about review jurisdiction for pre‑Feb 1, 2014 injuries, but denied relief on the vacancy‑filling question as premature.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Workers’ Compensation Commission may review Court of Existing Claims orders for injuries occurring before Feb 1, 2014 | Petitioners: Commission lacks authority; pre‑Feb 1 claims governed by prior law and review paths | Respondent: § 400(I)/(J) allows Commission review of those orders | Held: Commission has no jurisdiction to review orders/awards for injuries before Feb 1, 2014; pre‑existing review routes control |
| Proper review path for Court of Existing Claims orders for pre‑Feb 1, 2014 injuries | Petitioners: Parties retain prior review rights (three‑judge panel or direct Supreme Court review) | Respondent: New statute creates Commission review alternative | Held: Parties’ review rights preserved under preexisting law: three‑judge panel or Supreme Court (direct or after panel) |
| Whether all adjudication of pre‑Feb 1, 2014 claims is governed by law at time of injury | Petitioners: Article 5, § 54 and controlling precedent require application of law at time of injury | Respondent: Statutory changes alter review schemes prospectively | Held: All aspects of adjudication for pre‑Feb 1, 2014 injuries are governed by law in effect at time of injury; constitutional and statutory law cited support that rule |
| Whether the Court should resolve how vacancies on the Court of Existing Claims are filled | Petitioners: Requested guidance on appointments | Respondent: Not directly addressed | Held: Request denied as premature and speculative; Court declined to rule on future vacancy appointments |
Key Cases Cited
- King Manufacturing v. Meadows, 127 P.3d 584 (Okla. 2005) (held that adjudicative rules applicable at time of injury govern workers’ compensation claims)