State Office of Risk Mgmt. v. Martinez
539 S.W.3d 266
Tex.2017Background
- Martinez fell while working from home and sought workers’ compensation benefits from SORM.
- Administrative proceedings (benefit review officer, contested case hearing, appeals panel) focused on whether Martinez’s injury "arose out of" and "occurred in the course and scope" of employment (i.e., compensability) and whether she was disabled.
- Hearing officer found Martinez was "furthering the business" and "in the course of her work" but ultimately concluded the injury did not "arise out of nor occur in the course and scope of her employment," denying compensability and disability.
- Appeals panel reversed, finding Martinez was in the course and scope of employment, her injury arose out of employment, and she had disability from June 10, 2001 through the contested hearing date.
- Dispute reached the courts over whether the hearing officer’s factual findings conclusively established compensability and whether SORM was required to appeal specific factual findings to preserve judicial review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martinez’s injury both "arose out of" and "occurred in the course and scope" of employment (compensability) | Martinez: hearing officer’s findings that she was "furthering the business" and "in course of her work" establish both elements | SORM: hearing officer’s findings do not establish "arises out of" element; injury not compensable | Court: findings supported only the "course and scope" (furtherance) element; SORM could still contest the "arises out of" element — summary judgment for Martinez was properly denied |
| Whether hearing officer’s factual findings are binding/conclusive for compensability | Martinez: unappealed findings that she was furthering employer’s business conclusively establish compensability | SORM: may litigate statutory/other arguments despite unappealed factual findings | Court: party cannot pick favorable findings when they contradict the officer’s ultimate legal conclusion; findings are not dispositive on both elements |
| Whether SORM had to appeal each adverse factual finding to preserve judicial review (preservation) | Martinez: unchallenged findings should preclude SORM from seeking review on compensability | SORM: Labor Code requires appeal of "issues," not every factual finding; may challenge ultimate issues before appeals panel and in court | Court: Labor Code requires appeal of issues decided by hearing officer, not each factual finding; SORM did not forfeit its statutory arguments |
| Scope of judicial review in trial court | Martinez: trial court should defer to unchallenged factual findings supporting compensability | SORM: trial court performs modified de novo review of issues decided by appeals panel and need not defer to hearing officer’s findings | Court: trial court need not accept hearing officer’s factual findings on issues the appeals panel decided; remand to court of appeals to consider SORM’s statutory arguments |
Key Cases Cited
- Leordeanu v. Am. Prot. Ins. Co., 330 S.W.3d 239 (Tex. 2010) (explains the two-component compensability requirement: origination and furtherance)
- Seabright Ins. Co. v. Lopez, 465 S.W.3d 637 (Tex. 2015) (discusses "arises out of" and "course and scope" elements and their application)