In the Matter of the Worker's Compensation Claim of Mario Arellano, an Employee of L & L Enterprises: L & L Enterprises, 344 P.3d 249

Arellano, a Mexican national, applied to work for L&L, completed an I-9, and provided a New Mexico license and a social security card; he later admitted the SSN card was fake and that his I-9 attestation was false.
After ~4 months on the job he suffered a work-related lower-back injury and filed a Wyoming workers’ compensation claim.
The Division initially denied benefits citing lack of medical proof, injury definition issues, and lack of proof of work authorization/residency.
At OAH, the hearing examiner found Arellano injured in the course of employment but concluded he was not a covered “employee” because his authorization was based on fraudulent documents, and denied benefits.
The district court reversed the OAH, holding the statute’s 2005 amendment covers aliens whom the employer reasonably believes—based on documentation in its possession at hire and at injury—to be authorized to work; the Supreme Court affirmed.

Issue	Plaintiff's Argument (Arellano)	Defendant's Argument (L&L)	Held
Whether the OAH erred in concluding an alien who used false documents is not an “employee” under Wyo. Stat. § 27-14-102(a)(vii)	The statute covers him because L&L reasonably believed, based on documents in its possession, he was authorized to work	A fake SS card is not valid "documentation," and a belief based on false documents cannot be "reasonable"; thus he is not an employee	Affirmed district court: statute unambiguous—employer’s reasonable belief based on documentation in its possession controls; Arellano is an employee for WC purposes
Whether Arellano’s fraudulent misrepresentations in obtaining employment bar benefits	He did not misrepresent the injury or fraudulently obtain benefits; fraud in hiring does not defeat WC coverage	Fraud in obtaining employment independently precludes benefits or supports denial/reopening	Rejected L&L: statutes cited criminalize fraud to obtain benefits, not false statements at hiring; falsity at hire does not automatically bar WC benefits

Rodriguez v. Casey, 50 P.3d 323 (Wyo. 2002) (statutory interpretation seeks legislature’s intent and ordinary meaning)
Clements v. State ex rel. Dep’t of Workforce Servs., 326 P.3d 177 (Wyo. 2014) (de novo review of administrative statutory interpretation)
Stutzman v. Office of Wyoming State Eng’r, 130 P.3d 470 (Wyo. 2006) (court will not insert omitted language into statute)
McTiernan v. Jellis, 316 P.3d 1153 (Wyo. 2013) (statutes construed to avoid rendering any portion meaningless)
Herrera v. Phillipps, 334 P.3d 1225 (Wyo. 2014) (interpretation of § 27-14-102(a)(vii) supports that documentation in employer’s possession can create a factual issue on reasonable belief)
Felix v. State ex rel. Wyoming Workers’ Safety & Comp. Div., 986 P.2d 161 (Wyo. 1999) (discussed as pre-2005 statutory framework)