Brad Duke v. Ge Haier

CourtCourt of Appeals of Kentucky
DecidedMay 30, 2024
Docket2024 CA 000098
StatusUnknown

This text of Brad Duke v. Ge Haier (Brad Duke v. Ge Haier) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brad Duke v. Ge Haier, (Ky. Ct. App. 2024).

Opinion

RENDERED: MAY 31, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0098-WC

BRAD DUKE APPELLANT

PETITION FOR REVIEW OF A DECISION v. OF THE WORKERS’ COMPENSATION BOARD ACTION NO. WC-22-01269

GE HAIER; HONORABLE GRANT S. ROARK, ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD APPELLEES

AND

NO. 2024-CA-0140-WC

TONYA LONG APPELLANT

PETITION FOR REVIEW OF A DECISION v. OF THE WORKERS’ COMPENSATION BOARD ACTION NO. WC-21-61731

UNIVERSAL LINEN; HONORABLE PETER J. NAAKE, ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD APPELLEES OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; A. JONES AND LAMBERT, JUDGES.

THOMPSON, CHIEF JUDGE: Brad Duke and Tonya Long appeal from orders of

the Workers’ Compensation Board which affirmed orders from two Administrative

Law Judges (ALJs). The ALJs denied Appellants motions for their cases to go to

mediation. Appellants argue that mediation should be mandatory and not

discretionary. We disagree and find no error.

FACTS AND PROCEDURAL HISTORY

Appellants were each injured while at work and both sought workers’

compensation benefits. The specifics of their injuries are not relevant. After filing

their claims, Appellants, through counsel, petitioned their respective ALJ to be

transferred to mediation pursuant to a scheme set forth in Kentucky Revised

Statutes (KRS) 342.276 and 803 Kentucky Administrative Regulations (KAR)

25:300. The mediation program is moderated by current ALJs and must be

requested. At issue is Section 4 of 803 KAR 25:300, which states in relevant part:

Section 4. Procedures for Conduct of Mediation Proceedings.

(1) At any time after the claim has been initiated with the Department of Workers’ Claims, any party may file a motion with the administrative law judge to have the

-2- claim, or any part of the claim, referred to mediation under the program outlined in this administrative regulation. The motion shall identify the issues to be mediated.

(2) An opposing party shall have seven (7) calendar days to file a response to the motion seeking mediation.

(3) The administrative law judge shall either grant or deny the motion within ten (10) calendar days of the filing of the motion to refer to mediation.

(4) The parties may file a joint motion to refer to mediation. The administrative law judge shall order that the claim or parts of the claim be referred to mediation within seven (7) calendar days of the filing of the joint motion.

(5) The administrative law judge may refer a claim or part of a claim to mediation at any time after being assigned the claim.

(6) Upon the referral, the administrative law judge or the mediator shall confer with the parties for the purpose of scheduling the mediation. The mediator shall issue a mediation order within seven (7) calendar days of the referral which shall include:

(a) The date, time, allotted time, location of the mediation, and whether the mediation shall be conducted in person, by telephone, or by video conferencing technology;

(b) The required attendees of the mediation; and

(c) The issue(s) to be mediated.

In each of the cases before us, the appellant moved for mediation, but

the motions were denied. Both also petitioned for the ALJ to reconsider, but those

-3- petitions were also denied. Each case went to their respective ALJs in the usual

course and Appellants were awarded benefits. In fact, Appellants were awarded

the maximum amount of benefits they requested.

Appellants then appealed to the Board. They did not contest the

amount of benefits awarded, but did argue that they should have been allowed to

participate in mediation. The Board found that there was no error and affirmed.

The Board also affirmed the ALJs decisions regarding Appellants’ benefits. This

appeal followed.

ANALYSIS

On appeal, Appellants argue that mediation should be mandatory. In

the alternative, they argue that the ALJs abused their discretion in denying their

motions for mediation. We review issues surrounding the interpretation of statutes

and administrative regulations de novo. Commonwealth v. Long, 118 S.W.3d 178,

181 (Ky. App. 2003); All. for Kentucky’s Future, Inc. v. Envt’l & Pub. Prot.

Cabinet, 310 S.W.3d 681, 687 (Ky. App. 2009).

Here, we agree with the Board that whether to refer a case to

mediation is within the sound discretion of the ALJ. Section 4 of 803 KAR 25:300

states that an ALJ can either grant or deny a motion for mediation. 803 KAR

25:300 §4(3). It also states that an ALJ “may refer a claim or part of a claim” to

mediation. 803 KAR 25:300 §4(5). Both subsections indicate that an ALJ may

-4- refer a case to mediation, but it is not required. A plain reading of the regulation

indicates that mediation is discretionary.

We will now determine if the ALJs in these cases abused their

discretion in denying mediation. “The test for abuse of discretion is whether the

trial judge’s decision was arbitrary, unreasonable, unfair, or unsupported by sound

legal principles.” Commonwealth v. English, 993 S.W.2d 941, 945 (Ky. 1999).

In Mr. Duke’s case, after he moved for mediation, his employer

responded that it did not object to mediation; however, it requested a delay in

assigning mediation so that it could attempt to settle the claim with Mr. Duke first.

Additionally, the employer indicated that the report it received from the

independent medical evaluation it performed of Mr. Duke concurred with the

report of Mr. Duke’s medical expert on impairment rating, maximum medical

improvement date, and Mr. Duke’s capacity to return to work; therefore, there

were unlikely to be any contested issues.

The ALJ denied the motion for mediation due to the medical experts

of the parties agreeing on the major issues. The ALJ believed it would

unnecessarily take up a mediation slot since the issues were more or less resolved.

Mr. Duke then appealed to the Board. Mr. Duke did not appeal the benefits award,

but did raise the mediation issue. The Board agreed with the reasoning of the ALJ.

We too agree. The ALJ’s decision to deny Mr. Duke’s motion was reasonable

-5- under the circumstances. The medical experts for Mr. Duke and his employer

agreed on the major issues and Mr. Duke received the maximum amount of

benefits he requested. There was no error here.

As for Ms. Long, after she moved for mediation, her employer

responded that it did not object to mediation, but that it requested a private

mediator. A private mediator is allowed under 803 KAR 25:300 §5(2). Five days

after the employer’s response, the ALJ entered an order denying Ms. Long’s

motion to enter into the mediation program, but allowed the parties to enter into

private mediation as requested by the employer. The same day as that the ALJ

entered this order, Ms. Long objected to the private mediation and petitioned to

have mediation pursuant to 803 KAR 25:300 §4. The ALJ denied Ms. Long’s

renewed petition for mediation.

A hearing on Ms. Long’s compensation claim was held on March 2,

2023. That same day Ms. Long again moved for mediation. Ms. Long’s employer

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Related

Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Overstreet v. Overstreet
144 S.W.3d 834 (Court of Appeals of Kentucky, 2003)
Commonwealth v. Long
118 S.W.3d 178 (Court of Appeals of Kentucky, 2003)
Adkins v. Wrightway Readymix, LLC
499 S.W.3d 286 (Court of Appeals of Kentucky, 2016)

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Brad Duke v. Ge Haier, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brad-duke-v-ge-haier-kyctapp-2024.