TORRES v. SEABOARD FOODS, LLC
2016 OK 20
| Okla. | 2016Background
- Petitioner, a former employee, filed a workers' compensation claim alleging a cumulative-trauma injury requiring surgery.
- Employer argued the 180-day continuous-employment requirement in § 2(14) barred filing for a cumulative-trauma claim.
- Administrative Judge denied the claim; Workers' Compensation Commission affirmed.
- Court addressed the constitutionality of 85A O.S. Supp. 2018 § 2(14) and § 5 as applied to petitioner.
- Court held § 2(14) unconstitutional as applied, due to overinclusive/underinclusive classifications, and reversed/remanded for further proceedings.
- Court discussed the grand bargain but did not resolve § 5’s constitutionality on this record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 2(14)’s 180-day filing trigger violate due process? | Petitioner argues the duration predicate is unconstitutional. | Employer argues the 180-day trigger serves legitimate state interests (fraud prevention, cost control). | Yes; § 2(14) unconstitutional as applied. |
| Are § 2(14)’s classifications overinclusive/underinclusive and thus irrationally related to state interests? | Classifies injures by employment duration to file a claim, harming innocents. | Classification rationally related to fraud prevention and cost reduction. | Yes; classifications are irrational; violate due process. |
| Does § 5's immunity coupled with § 2(14) violate due process/equal protection by denying all remedies? | Argues the combo deprives petitioner of any recovery. | Argues the legislature’s framing fits within the AWCA framework. | Court reverses § 2(14) application; ambiguities with § 5 not resolved on this record. |
| Is remand appropriate to address constitutionality in light of the grand bargain? | Requests full vindication of rights under the grand bargain. | Arguments about the grand bargain are not dispositive on remand. | Remand to proceed consistent with the opinion; no need to address § 2(14) grand bargain here. |
Key Cases Cited
- Jimenez v. Weinberger, 417 U.S. 628 (U.S. Supreme Court 1974) (due process/equal protection rational-basis discussion; spurious claims)
- United States R.R. Retirement Bd. v. Fritz, the cited portions in text not a formal reporter citation (U.S. Supreme Court) (principles about legislative reasons and classification powers (used for framework))
- Updegraff (Board of Regents v. Updegraff), 237 P.2d 131 (Okla. 1952) (police power limits and rational relation test in Oklahoma due process)
- BMW of North America v. Gore, 517 U.S. 559 (U.S. Supreme Court 1996) (substantive due process limits on punitive damages; rational relation to state interests)
- Gladstone v. Bartlesville Indep. School Dist. No. 30, 66 P.3d 442 (Okla. 2003) (equal protection concerns in comparing governmental tort immunities)
- Parret v. UNICCO Service Co., 127 P.3d 572 (Okla. 2005) (grand bargain context and legislative modification of private rights)