Shawn Murphy v. Fairbanks North Star Borough, 494 P.3d 556

In 1998 Shawn Murphy injured his back at work; he received temporary total disability, underwent surgery, and later entered reemployment training.
After doctors assessed medical stability in 2000–2001, Murphy received permanent partial impairment payments based on impairment ratings (Dr. Goldthwaite: 30% using AMA 4th ed.; Dr. Cobden: 23% using AMA 5th ed.).
Compensation reports filed with the Board were inconsistent/partly blank; the Borough paid impairment benefits in installments and then began reemployment stipend payments in May 2001.
Murphy did not file a written claim for additional impairment benefits until 2017, alleging underpayment and wrong AMA Guides edition; the Borough asserted AS 23.30.105(a)’s two-year statute of limitations.
The Workers’ Compensation Board and the Appeals Commission held Murphy’s 2017 impairment claim was time-barred; they also denied $993.75 in paralegal costs because paralegal affidavits required by 8 AAC 45.180(f)(14) were not filed.
The Alaska Supreme Court affirmed the Commission: impairment claims are subject to the two-year limitations period and the paralegal-affidavit regulation is valid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AS 23.30.105(a)’s two-year limitations period applies to claims for permanent partial impairment	Murphy: The statute limits only "compensation for disability," and impairment is distinct from disability, so impairment claims are not time-barred	Borough: The 1988 amendments and subsequent history show impairment (an indemnity benefit) is governed by the same two-year limit; voluntary payments toll the period	Court: Ambiguity resolved by legislative history and policy — impairment claims are subject to AS 23.30.105(a)’s two-year limit; voluntary payments toll the period per statute
Validity of 8 AAC 45.180(f)(14) requiring paralegal affidavits to recover paralegal costs	Murphy: Regulation conflicts with statute and could force paralegals to attest to unauthorized practice of law (self-incrimination)	Borough: Regulation is a valid procedural rule implementing AS 23.30.145; affidavit documents services performed under attorney supervision and does not compel incrimination	Court: Regulation is a valid procedural implementation of the statute and does not violate the Constitution; Commission properly denied paralegal costs absent affidavits

Alaska Airlines, Inc. v. Darrow, 403 P.3d 1116 (Alaska 2017) (distinguishes impairment from disability and analyzes 1988 statutory amendments)
Louie v. BP Exploration (Alaska), Inc., 327 P.3d 204 (Alaska 2014) (statute in effect on date of injury generally governs claim)
Williams v. Safeway Stores, 525 P.2d 1087 (Alaska 1974) (discussion of whether "compensation" includes medical benefits)
Atlantic Richfield Co. v. State, 723 P.2d 1249 (Alaska 1986) (characterizing paralegal expenses as costs)
Harris v. Millennium Hotel, 330 P.3d 330 (Alaska 2014) (indemnity benefits characterization and statutory interpretation principles)