Coates v. Fallin
2013 OK 108
| Okla. | 2013Background
- In 2013 the Oklahoma Legislature enacted SB 1062, repealing the prior Workers' Compensation Code and replacing it with the Administrative Workers' Compensation Act (85A O.S.) plus related Opt‑Out (Oklahoma Employee Injury Benefit Act) and arbitration and transition provisions; effective Feb. 1, 2014.
- Petitioners challenged SB 1062 on multiple constitutional grounds, principally that the bill violated the single‑subject rule (Art. 5, § 57) and that various provisions deny due process and equal protection.
- The Oklahoma Supreme Court assumed original jurisdiction to decide the constitutional challenge.
- The majority held SB 1062 is not unconstitutional as a multiple‑subject (log‑rolling) bill and declined further rulings absent a justiciable case or controversy.
- Separate opinions (concurring/dissenting in part) expressed concerns about facial constitutional defects in several provisions: differential appellate procedures for Opt‑Out claimants, lack of impartial decisionmakers, inadequate record development, exclusive‑remedy language combined with noncoverage (mental‑injury and same‑sex spouse death benefits), and unequal treatment of certain permanent partial disability awards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Single‑subject / log‑rolling (Art. 5, § 57) | SB 1062 contains multiple unrelated measures joined to enact substantive changes improperly. | All provisions are germane to workers' compensation and form an integrated code for the subject. | Court: SB 1062 is germane to a single theme (workers' compensation) and does not violate the single‑subject rule. |
| Opt‑Out appellate procedure / impartiality (due process) | Opt‑Out claimants face initial review by an employer‑selected committee (appearance of partiality) and thus lack a neutral adjudicator. | Legislature may set differing procedures for Opt‑Out plans; minimum protections are provided and judicial review is available. | Not decided by majority on merits; concurrence(s) would find the Opt‑Out appeals process constitutionally defective for lack of impartial tribunal and would sever provisions. |
| Record development and standard of review for Opt‑Out appeals | Opt‑Out process limits record development to employer‑selected internal appeal; Commission and Supreme Court review are confined to that record and to a vague "contrary to law" standard, denying meaningful appellate review. | The Act prescribes minimum procedures, and the Commission/Supreme Court retain review authority; many challenges are not ripe and should be addressed when cases arise. | Majority declined to reach these claims now; concurring opinions flagged insufficiency of record/development and ambiguity of standard, urging judicial scrutiny/severance where necessary. |
| Substantive equal‑protection / special‑law complaints (exclusive remedy, mental injury exclusion, same‑sex spouse death benefits, PPD employer deductions) | Combining exclusive‑remedy language with exclusions (mental injuries not accompanied by physical injury; denying death benefits to same‑sex spouses) and unequal treatment of PPD deductions creates unconstitutional special laws and denies due process/equal protection. | Legislature may define coverage and remedies; exclusive remedy is a valid legislative design for workers' compensation. | Majority did not adjudicate these substantive challenges here; a dissent/ concurrence in part would sever or strike specific provisions (exclusive‑remedy text where it immunizes employers for uncompensated harms; denial of death benefits to same‑sex spouses; unequal PPD deduction scheme). |
Key Cases Cited
- Glasco v. State ex rel. Okla. Dep’t of Corr., 188 P.3d 177 (Okla. 2008) (statutes presumed constitutional; courts must uphold unless clearly inconsistent with the Constitution)
- Matter of Application of Okla. Dev. Fin. Auth. for Approval of Bonds, 312 P.3d 926 (Okla. 2013) (single‑subject/log‑rolling test: whether provisions share a common, closely akin theme)
- Burrell v. Burrell, 192 P.3d 286 (Okla. 2007) (judicial restraint: courts will not rewrite statutes under policy disagreements)
- Boston Ave. Mgt., Inc. v. Associated Resources, Inc., 152 P.3d 880 (Okla. 2007) (similar principle on giving effect to legislative acts)
- Head v. McCracken, 102 P.3d 670 (Okla. 2004) (statutory construction and deference to legislature)
- Stanley v. Mowery, 207 P.2d 277 (Okla. 1949) (legislature may delegate details of employee protection to administrative entities)
- Cotner v. Golden, 136 P.3d 630 (Okla. 2006) (due‑process requires opportunity to develop record adequate for meaningful appellate review)
- State ex rel. Bennett v. Childers, 105 P.2d 762 (Okla. 1940) (requirement of impartial, neutral adjudicator as part of due process)