Provo City v. Utah Labor Commission
345 P.3d 1242
Utah2015Background
- Duane Serrano, a Provo City facility service technician, was injured in a work-related car accident and later alleged the accident aggravated a congenital spinal condition causing chronic pain.
- Serrano continued working for ~4 years, then quit when reassignment was unavailable and applied for permanent total disability (PTD) benefits under Utah Code § 34A-2-413.
- The ALJ initially denied PTD after considering ~20 medical evaluations with conflicting opinions (some found malingering; one medical expert found PTD). Serrano sought review.
- The Utah Labor Commission set aside the ALJ’s denial, ordered a medical panel review, and remanded for a new decision considering the full record.
- On remand, after the medical panel issued a report, the ALJ awarded PTD benefits; the Labor Commission affirmed. The Workers Compensation Fund (WCF) appealed, raising challenges to the PTD findings, the ALJ’s changed result after remand, and the proper onset date given adjudicative delay.
Issues
| Issue | Plaintiff's Argument (Serrano) | Defendant's Argument (WCF) | Held |
|---|---|---|---|
| Whether Serrano proved the statutory elements for PTD (six-element framework of § 34A-2-413) | Serrano: evidence (medical panel, testimony) shows significant impairment, not gainfully employed, limited basic work activities, unable to perform former or reasonably available work, and accident caused disability | WCF: record does not support any of the six elements; evidence favors ability to work and causation by congenital condition, not accident | Court: Affirmed — substantial evidence supports findings on elements (third–fifth reviewed for substantial evidence; first also under substantial evidence; sixth legal causation reviewed de novo and satisfied) |
| Standard of review for PTD elements | Serrano: ALJ/Commission findings entitled to deference | WCF: challenged findings as unsupported | Court: third–fifth elements are factual (substantial evidence); first (significant impairment) is mixed but reviewed for factual sufficiency (substantial evidence); sixth (legal causation where preexisting condition exists) reviewed de novo as a legal-method challenge |
| Whether ALJ abused discretion by reaching a different result on remand | Serrano: medical panel provided new evidence; remand directed reconsideration | WCF: ALJ improperly reversed initial denial after remand | Court: No abuse — medical panel report was new evidence and remand authorized reweighing; WCF forfeited detailed legal challenge |
| Whether delay in final adjudication justifies altering benefit onset date | Serrano: delay was administrative, not claimant-caused; onset should not be modified | WCF: delay prejudices fund; onset date should be modified under equitable principles | Court: Declined to modify onset — Employers’ Reinsurance Fund precedent (which reduced benefits where claimant’s delay prejudiced fund) is inapplicable because delay here was caused by the adjudicative system, not claimant |
Key Cases Cited
- Murray v. Utah Labor Comm’n, 308 P.3d 461 (Utah 2013) (standard for review of administrative findings and causation framework with preexisting conditions)
- In re Adoption of Baby B., 308 P.3d 382 (Utah 2012) (mixed questions of law and fact and standards of review)
- Allen v. Industrial Commission, 729 P.2d 15 (Utah 1986) (aggravation of preexisting condition compensable; legal causation requirement)
- Employers’ Reinsurance Fund v. Labor Commission, 289 P.3d 572 (Utah 2012) (equitable modification of benefit onset where claimant’s delay prejudiced fund)
- Becker v. Sunset City, 309 P.3d 223 (Utah 2013) (substantial-evidence review and deference to administrative factfinding)
- Martinez v. Media-Paymaster Plus, 164 P.3d 384 (Utah 2007) (PTD element review: fourth and fifth elements are factual questions)
- State v. Pena, 869 P.2d 932 (Utah 1994) (distinguishing factual questions from mixed questions of law and fact)