715 S.W.3d 734
Tex.2025Background
- Rita Oteka, a faculty member at The University of Texas Rio Grande Valley, was struck by a university police vehicle after voluntarily attending a commencement ceremony to support former students.
- The University, as a self-insured workers’ compensation employer, initially denied her injury was work-related, based on Oteka’s own pursuit of personal insurance and lack of supporting medical evidence.
- Oteka did not file a workers’ compensation claim and later sued the University for negligence.
- The University asserted the exclusive-remedy defense, arguing her injury was in the course and scope of employment, barring her lawsuit under the Texas Workers’ Compensation Act.
- The University’s claims administrator then reversed, accepting the injury as compensable after over two years; the University claimed the Division of Workers’ Compensation had exclusive jurisdiction to decide the work-relatedness of the injury.
- The trial court and court of appeals denied the University's plea to jurisdiction, holding the district court retained authority to decide the issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the Division have exclusive jurisdiction to decide if Oteka’s injury was work-related when raised as an affirmative defense? | District court can decide; Oteka’s relief isn't predicated on WC benefits, and she never filed a claim. | Division has sole authority to decide course-and-scope/work-relatedness in any such dispute. | No exclusive administrative jurisdiction; district court can decide when employee doesn't seek WC benefits. |
| Must Oteka exhaust administrative remedies before pursuing her negligence lawsuit? | Not required, as no workers’ comp claim was made and lawsuit does not depend on WC entitlement. | Yes; a compensation claim must be filed and resolved administratively even if the claim is disputed by the employer's defense. | Not required to exhaust admin remedies since relief sought is not based on WC benefits’ entitlement. |
| Is there a statutory mechanism to bring a course-and-scope issue before the Division absent a compensation claim? | No such mechanism exists—employees seeking non-WC remedies should not be forced to file claims for benefits they do not seek. | The Act’s system is comprehensive, so such disputes should go to the Division regardless. | Absence of such mechanism is determinative—the Act doesn't require or support this process for employer’s defenses. |
| Does the district court have subject-matter jurisdiction to hear Oteka’s claim? | Yes; the Workers’ Compensation Act does not expressly remove that jurisdiction here. | No; exclusive jurisdiction rests with the Division. | Yes; presumption favors district court jurisdiction unless clearly divested by legislative action. |
Key Cases Cited
- Am. Motorists Ins. Co. v. Fodge, 63 S.W.3d 801 (Tex. 2001) (only the Division can initially determine claimant’s entitlement to compensation benefits, but not all claims fall under its exclusive jurisdiction)
- Walls Reg’l Hosp. v. Bomar, 9 S.W.3d 805 (Tex. 1999) (work-relatedness and exclusive-remedy can be resolved by the courts in certain negligence actions)
- City of Bellaire v. Johnson, 400 S.W.3d 922 (Tex. 2013) (district courts generally have jurisdiction over injury claims unless clearly displaced)