In the Matter of the Worker's Compensation Claim of Michael Vinson: Tata Chemicals Soda Ash Partners, Ltd. v. Michael Vinson, 450 P.3d 234

Michael Vinson scraped his knuckle at work and developed necrotizing fasciitis requiring extensive hospitalization, surgery, and antibiotics.
The Workers' Compensation Division initially deemed the injury compensable; employer Tata contested coverage, asserting the infection fell under the communicable disease exclusion.
The Office of Administrative Hearings (OAH) issued a final decision on January 30, 2018, granting summary judgment for Tata and concluding the infection was not compensable.
Under the rules, the 30-day period to file a petition for judicial review (plus mail extension and weekend/holiday rules) made March 5, 2018 the deadline; Vinson filed on March 6, 2018 (one day late).
The district court reversed the OAH decision on the merits without addressing timeliness or whether excusable neglect extended the filing period.
The Wyoming Supreme Court held that timeliness is jurisdictional, remanded to the district court to determine within 45 days whether excusable neglect extended Vinson’s filing period, and stayed this appeal pending that determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court had jurisdiction over Vinson's petition for review	Vinson proceeded in district court and obtained a merits reversal; the record does not show he argued timeliness in the district court	Tata argued the petition was filed one day late and the district court therefore lacked jurisdiction	Court held timely filing is jurisdictional and remanded for the district court to decide whether excusable neglect extended the filing period
Whether the late filing can be excused under W.R.A.P. 12.04(b) (excusable neglect)	Implicit: Vinson could assert excusable neglect to preserve jurisdiction	Tata can challenge any finding of excusable neglect on appeal	Court instructed the district court to decide excusable neglect within 45 days; if none found, district court should dismiss and appeal procedures follow; if found, Tata may appeal and the Supreme Court will consolidate appeals

Chevron U.S.A., Inc. v. Dep’t of Revenue, 155 P.3d 1041 (Wyo. 2007) (timely filing is jurisdictional; excusable neglect reviewed for abuse of discretion)
Sellers v. Emp’t Sec. Comm’n of Wyo., 760 P.2d 394 (Wyo. 1988) (30-day review period runs from date decision is mailed)
Stagner v. Wyo. State Tax Comm’n, 642 P.2d 1296 (Wyo. 1982) (timely filing of petition for review is mandatory and jurisdictional)