371 P.3d 477
Okla.2016Background
- Cynthia Robinson, a nurse's aide, slipped on an icy sidewalk during her lunch break and sought workers' compensation for neck, left shoulder, and left knee injuries.
- Employer admitted employment but argued the injury was not in the course and scope of employment under 85A O.S. Supp. 2013 § 2(13); ALJ found the injury not compensable.
- Robinson asserted that if § 2(13) barred her claim, the statute was an unconstitutional special law that denied her a remedy; the ALJ declined to rule on constitutionality.
- The Workers' Compensation Commission affirmed the ALJ, and the Court of Civil Appeals declined to address the constitutional claim, suggesting a district-court declaratory action.
- The Oklahoma Supreme Court granted certiorari to decide whether the Commission has authority to adjudicate as-applied constitutional challenges to Title 85A provisions in proceedings before it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Workers' Compensation Commission may decide an as-applied constitutional challenge to a Title 85A provision in a claims proceeding | Robinson: Commission must decide constitutional application of § 2(13) when raised in a claim | Employer/Commission: Constitutional questions must be decided by courts, not the administrative Commission | The Commission has power, when acting adjudicatively, to decide whether a Title 85A provision is unconstitutional as applied to a particular party in a proceeding before it |
| Whether a party must pursue a separate declaratory judgment in district court to resolve constitutionality of a workers' compensation statute | Robinson: No; AWCA provides the exclusive forum and relief should be adjudicated in the Commission | Commission/COCA: District court declaratory action is appropriate | COCA was wrong; AWCA limits district-court declaratory review and the Commission is the appropriate first forum for as-applied challenges |
| Whether the Commission may adjudicate facial constitutionality of statutes | Robinson: (not argued as primary relief) | State: Legislature cannot delegate power to render facial invalidation to the Commission | The Commission may not decide facial invalidity; only courts may declare a statute facially unconstitutional |
| Appellate reviewability of constitutional rulings by the Commission | Robinson: Commission decisions on constitutionality should be reviewable on appeal | Commission: asserted limitation but acknowledged appellate review exists | Decisions by the Commission on as-applied constitutional issues are subject to review by the Oklahoma Supreme Court (and Court of Civil Appeals when properly assigned) |
Key Cases Cited
- Dow Jones & Co., Inc. v. State ex rel. Oklahoma Tax Comm'n, 787 P.2d 843 (Okla. 1990) (addressing limits on administrative agencies declaring statutes unconstitutional)
- Yocum v. Greenbriar Nursing Home, 130 P.3d 213 (Okla. 2005) (discussing administrative bodies acting in adjudicative capacity)
- Jackson v. Indep. Sch. Dist. No. 16 of Payne Cnty., 648 P.2d 26 (Okla. 1982) (defining quasi‑judicial proceedings and agency fact‑finding)
- Adams v. Iten Biscuit Co., 162 P. 938 (Okla. 1917) (historical discussion of the workers' compensation remedy as prompt and exclusive)
- Cline v. Oklahoma Coalition for Reprod. Justice, 313 P.3d 253 (Okla. 2013) (Supreme Court authority on courts as ultimate interpreters of state law)