Hyde v. Cotton
2011 OK 31
| Okla. | 2011Background
- Decedent Hyde died August 27, 2008 from an on-the-job incident; Employer admits death occurred in the course of employment.
- Mother Judy Hyde filed a death benefits claim in the Workers' Compensation Court on September 15, 2008, on behalf of four children, with Mother acting as guardian for one child.
- Angela Cotton claimed to be the Decedent's common-law wife and filed a separate death benefits claim in the Workers' Compensation Court on November 26, 2008, designating herself as Personal Representative.
- District Court in Lincoln County probate proceedings found Hyde and Cotton were common-law married, Cotton was Decedent's surviving spouse and heir, and appointed co-administrators of the estate.
- In the Workers' Compensation Court, Cotton moved for summary judgment after discovery issues; the trial judge granted the motion; three-judge panel affirmed; this prompted appeals by Employer and Mother.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is summary judgment permissible in Workers' Compensation proceedings? | Employer argues no; WCC lacks authority. | WCC should adopt available district-court procedures. | Summary judgment is not available in WCC proceedings. |
| Whether the district court's common-law marriage finding binds the WCC? | District court finding should bind due to issue preclusion/privity. | Binding should apply; WCC not free to relitigate. | District court's common-law marriage finding bound the WCC. |
| Does Cotton meet the statutory surviving-spouse definition in the WCA? | Common-law wife status alone suffices for surviving-spouse benefits. | Surviving-spouse status requires meeting statutory elements beyond marital status. | Cotton qualifies as surviving spouse under the statute. |
| Are Employer and Mother in privity for preclusion purposes? | Employer and Mother share identical interests in the outcome. | They do not share the same interest in probate vs. WC benefnavigation. | Employer and Mother are in privity; probative district court ruling binds WC Court. |
| What is the remedy given the holdings? | Remand to WC Court for proper award. | vacate improper summary judgment; proceed with proper WC procedure. | Remand to Workers' Compensation Court for award consistent with opinion. |
Key Cases Cited
- Snyder v. Smith Welding & Fabrication, 1986 OK 35, 746 P.2d 168 (OK 1986) (summary-judgment in WC Court not authorized; analogous to other improper procedures)
- Lee v. Harvey, 1945 OK 63, 156 P.2d 134 (OK 1945) (general presumption of sufficient evidence to sustain judgments)
- Powers v. Dist. Ct. of Tulsa Cnty., 2009 OK 91, 227 P.3d 1060 (OK 2009) (unlimited-jurisdiction judgments can bind limited-jurisdiction courts)
- Wilson v. City of Tulsa, 2004 OK CIV APP 44, 91 P.3d 673 (OK Civ. App. 2004) (privity requires identity of interest)
- State ex rel. Dep’t of Transp. v. Little, 2004 OK 74, 100 P.3d 707 (OK 2004) (preclusion governs relitigation between the same parties or privies)
- Anco Mfg. & Supply Co., Inc. v. Swank, 1974 OK 78, 524 P.2d 7 (OK 1974) (prior judgment precludes subsequent WC action when within scope)