MAXWELL v. SPRINT PCS, 2016 OK 41

Background

Maxwell, Smith, Hoffman, and Majors suffered work-related injuries (knees/hands) admitted by employers and reached maximum medical improvement, then returned to pre-injury jobs and wages.
Each claimant sought permanent partial disability (PPD) awards; ALJs/Commission applied AMA Guides (6th Ed.) and often rated impairment to the body as a whole, awarded small PPD sums.
Under 85A O.S. Supp. § 45(C)(5), the Commission deferred PPD awards while an employee works in a pre-injury/equivalent job, reducing the award by 70% of average weekly wage per week worked; employers can limit payment by reemployment or termination (misconduct exception).
Maxwell appealed, arguing (among other things) that scheduled members (legs/hands) are exempt from the AMA Guides and that the deferral scheme is unconstitutional; the Commission affirmed and the Supreme Court retained the cases as companions.
The Oklahoma Supreme Court held scheduled members are exempt from the AMA Guides and struck down § 45(C)(5)(a–e) as a due-process violation and the application of deferral to only certain claimants (via § 46(C)) as an unconstitutional special law.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do the AMA Guides apply to scheduled-member injuries (e.g., leg, hand)?	Claimants: scheduled members are exempt; injuries should be rated under scheduled-member provisions, not AMA Guides.	Employers/AG: AMA Guides apply generally to impairment rating (Commission had used them).	Held: Scheduled members are exempt from the AMA Guides under AWCA; conversion to body-as-a-whole using AMA Guides was improper.
Should PPD for scheduled-member injuries be awarded to the member (leg/hand) or to the body as a whole?	Claimants: injury to scheduled member must be compensated per §46 schedule (weeks for member).	Commission/AG: used AMA Guides and conversion tables to rate to body as a whole.	Held: PPD for scheduled members must be awarded to the scheduled member per §46(A); partial loss allocated proportionally to the scheduled-member weeks.
Is the PPD deferral scheme in §45(C)(5) (deferring/forfeiting awards while employee returns to work) constitutional under due process?	Claimants: Deferral deprives vested property without adequate process; results in arbitrary forfeiture before hearing and reintroduces fault into a no-fault scheme.	AG: Deferral ties benefits to actual loss of earning capacity and prevents windfalls when the employee returns to work; promotes retention.	Held: §45(C)(5)(a–e) is an unconstitutional violation of due process (Art. 2, §7); those subsections are stricken.
Is applying deferral only to "other cases" (injuries to body as a whole) while excluding scheduled-member awards a permissible classification (special-law challenge under Art. 5, §59)?	Claimants: Selective deferral creates an arbitrary subclass and unequal treatment without reasonable basis.	AG: Legislature can distinguish classes; purpose was to align benefits with loss of earning capacity.	Held: The differential application (via §46(C)) is an unconstitutional special law; that portion of §46(C) making deferral applicable to body-as-a-whole injuries is invalid.

Key Cases Cited

State ex rel. Protective Health Servs. v. Vaughn, 222 P.3d 1058 (Okla. 2009) (standard for statutory interpretation; de novo review of legal questions)
Daffin v. State ex rel. (Daffin), 251 P.3d 741 (Okla. 2011) (due-process principles for property interests created by statute)
Special Indem. Fund v. Figgins, 831 P.2d 1379 (Okla. 1992) (construction and longstanding meaning of scheduled-member exception)
Grant v. Goodyear Tire & Rubber Co., 5 P.3d 594 (Okla. 2000) (special-law doctrine; subclass treatment must have practical basis)
Evans & Assocs. Util. Servs. v. (Evans), 264 P.3d 1190 (Okla. 2011) (workers' compensation purpose: compensate for loss of earning power)
Bristow Cotton Oil Co. v. State Indus. Com'n, 188 P. 658 (Okla. 1920) (interpretation of "loss of use" / permanent loss of use concept)