Basic Construction Company v. Hamilton

CourtCourt of Appeals of Virginia
DecidedAugust 17, 1999
Docket2844981
StatusUnpublished

This text of Basic Construction Company v. Hamilton (Basic Construction Company v. Hamilton) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Basic Construction Company v. Hamilton, (Va. Ct. App. 1999).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Willis, Bray and Annunziata Argued at Norfolk, Virginia

BASIC CONSTRUCTION COMPANY AND FARMINGTON CASUALTY COMPANY/ TRAVELERS PROPERTY CASUALTY COMPANY MEMORANDUM OPINION * BY v. Record No. 2844-98-1 JUDGE RICHARD S. BRAY AUGUST 17, 1999 DEBBIE HAMILTON

FROM THE VIRGINIA WORKERS’ COMPENSATION COMMISSION

Francis G. Marrin (Law Office of Roger S. Mackey, on brief), for appellants.

John H. Klein (Montagna, Klein & Camden, L.L.P., on brief), for appellee.

Basic Construction Company and Travelers Property Casualty

Company (collectively employer) appeal a decision of the

Workers’ Compensation Commission (commission) awarding benefits

under the Workers’ Compensation Act (Act) to Debbie Hamilton

(claimant). Employer complains that the commission erroneously

(1) awarded claimant benefits after the deputy commissioner had

denied relief and claimant had made no timely request for

review, (2) determined that the claim was not barred by material

misrepresentations when seeking the employment, (3) found that

the injury resulted from a work-related accident, and (4)

concluded that claimant made a reasonable effort to market her

* Pursuant to Code § 17.1-413, recodifying Code § 17-116.010, this opinion is not designated for publication. residual capacity. Finding no error, we affirm the commission’s

award.

The parties are fully conversant with the record, and this

memorandum opinion recites only those facts necessary to a

disposition of the appeal. On appeal, we view the evidence in

the light most favorable to the party prevailing below, claimant

in this instance. See Crisp v. Brown’s Tysons Corner Dodge, Inc.,

1 Va. App. 503, 504, 339 S.E.2d 916, 916 (1986). Factual findings

by the commission that are supported by credible evidence are

conclusive and binding upon this Court on appeal. See Rose v.

Red’s Hitch & Trailer Servs., 11 Va. App. 55, 60, 396 S.E.2d 392,

395 (1990).

I.

On February 12, 1996, claimant lodged a claim with the

commission seeking benefits pursuant to the Act for certain

accidental injuries she suffered on August 28, 1995. A hearing

was conducted by Deputy Commissioner Wilder on April 11, 1997,

and, in defense of the application, employer asserted that (1)

claimant had misrepresented material facts on her employment

application, (2) her injuries were not occasioned by a

work-related accident, (3) she had failed to provide proper notice

of the alleged incident, and (4) she had not marketed her residual

capacity. By opinion dated May 16, 1996, the deputy found that

claimant had neither materially misrepresented her physical

condition nor failed to report the accident to the prejudice of

- 2 - employer, but, nevertheless, denied the claim, concluding that

claimant had not established that the accident “caused her injury

or disability.”

By letter dated May 20, 1997, claimant requested the deputy

to reconsider, “taking specific note” of correspondence in

evidence from her treating physician, Dr. Grasinger. In response,

the deputy wrote both parties on June 2, 1997:

I have received [claimant’s counsel’s] May 20, 1997 request for reconsideration. In order to give the parties some certainty regarding time limitations for review requests, I am granting the request to reconsider my May 16, 1997 Opinion; however, I cannot yet rule on the merits of the claim because the file has been returned to Richmond. I have requested the file and will issue a ruling on the merits as soon as I have an opportunity to review the evidence.

After further review, the deputy resolved all issues in favor of

claimant and awarded benefits by opinion issued May 20, 1998.

Employer requested review of the decision by the full

commission, moving for enforcement of the deputy’s original

opinion and otherwise challenging the award. Employer contended

that, when the deputy did not vacate his earlier ruling within

twenty days, it became final pursuant to Code §§ 65.2-705,

65.2-706 and Commission Rule 3.1, thereby divesting him of

jurisdiction to re-decide the claim by the May 20, 1998 opinion.

In the alternative, employer asserted the defenses previously

considered by the deputy. The commission concluded that the

“Deputy Commissioner’s June 2, 1997, letter issued within twenty

- 3 - days, vacated the original opinion” and affirmed the decision of

May 20, 1998, resulting in the instant appeal by employer.

II.

Employer acknowledges on brief that “[t]he Deputy

Commissioner who has rendered an initial ruling retains

jurisdiction over the claim for twenty (20) days” and “may vacate

or amend [the] original opinion” within such period. See Code

§ 65.2-705(A); Rule 3.1, Rules of the Workers’ Compensation

Commission. However, employer contends that the deputy’s June 2,

1997 response to claimant’s motion to reconsider neither vacated

nor amended the original decision, resulting in finality after the

expiration of twenty days. See Code § 65.2-706. Employer’s

argument overlooks the deference accorded to the commission’s

interpretation of its orders.

“[I]t is within the commission’s discretion to . . . examine

the [order] of the deputy commissioner . . . to ascertain the

result intended,” and we will not disturb the commission’s

determination unless “arbitrary or capricious.” Rusty’s Welding

Service, Inc. v. Gibson, 29 Va. App. 119, 130, 510 S.E.2d 255,

260-61 (1999) (en banc). The commission determined that the

deputy’s correspondence to counsel, “granting the request to

reconsider [the earlier] opinion” and promising to “issue a ruling

on the merits” after further “review of the evidence,” “in effect,

vacated the original opinion.” The commission, therefore, decided

that the deputy “had jurisdiction to issue the May 20, 1998,

- 4 - opinion.” Our review of the record discloses ample support for

the commission’s interpretation of the deputy’s initial

disposition of claimant’s request, and we decline to disturb it on

appeal.

Employer next asserts that claimant is barred from benefits

because she misrepresented her physical capacity by not responding

to the inquiry, “Do you know of, or have you any physical

disability that could or would hinder or limit your activity while

working in your trade?” which appeared on her employment

application. Claimant testified that she “really overlooked” the

question in issue, but would have “marked no” in response because,

“[i]n [her] opinion, the three surgeries [she] had on [her] back

. . . would [not] act as a limiting factor on what [she] could do

as a laborer.” We recognize that

[a]n employee’s false representation in an employment application will bar a later claim for workers’ compensation benefits if the employer proves that 1) the employee intentionally made a material false misrepresentation; 2) the employer relied on that misrepresentation; 3) the employer’s reliance resulted in the consequent injury; and 4) there is a causal relationship between the injury in question and the misrepresentation.

Falls Church Const. Co. v.

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Crisp v. Brown's Tysons Corner Dodge, Inc.
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Ingersoll-Rand Co. v. Musick
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