Brian Doyal v. Vernon Parish School Board

CourtLouisiana Court of Appeal
DecidedFebruary 7, 2007
DocketWCA-0006-1088
StatusUnknown

This text of Brian Doyal v. Vernon Parish School Board (Brian Doyal v. Vernon Parish School Board) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brian Doyal v. Vernon Parish School Board, (La. Ct. App. 2007).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

06-1088

BRIAN DOYAL

VERSUS

VERNON PARISH SCHOOL BOARD

**********

APPEAL FROM THE OFFICE OF WORKERS’ COMPENSATION - DISTRICT 2 PARISH OF RAPIDES, NO. 04-05616 JAMES L. BRADDOCK, WORKERS’ COMPENSATION JUDGE

MARC T. AMY JUDGE

Court composed of Marc T. Amy, J. David Painter, and James T. Genovese, Judges.

AFFIRMED.

Maria A. Losavio Losavio Law Firm, LLC Post Office Box 12420 Alexandria, LA 71315-2420 (318) 767-9033 COUNSEL FOR PLAINTIFF/APPELLEE: Brian Doyal

Stacy C. Auzenne Auzenne Law Firm, LLC Post Office Drawer 11817 Alexandria, LA 71315-1817 (318) 880-0087 COUNSEL FOR DEFENDANT/APPELLANT: Vernon Parish School Board AMY, Judge.

The employee allegedly sustained injuries in an accident related to his

employment as a cafeteria worker. The employer terminated benefits and sought a

determination that the employee forfeited benefits due to what it asserted were

fraudulent statements concerning the claim and failure to timely report wages from

outside employment. The employee sought reinstatement of benefits as well as

penalties and attorney’s fees. The workers’ compensation judge found in favor of the

employee and awarded the relief sought. The employer appeals. The employee

answers the appeal. We affirm.

Factual and Procedural Background

The record establishes that Brian Doyal was employed by the Vernon Parish

School Board as a cafeteria cook at East Leesville Elementary School. Mr. Doyal

asserts that he sustained injury on October 9, 2003 when a sheet pan rack toppled

against him and knocked him to the ground. He contends that a faulty wheel caused

the accident.

Marsha Mayo, the cafeteria’s assistant head cook, explained that she was

nearby and that she responded to Mr. Doyal’s moaning. She testified that she and Mr.

Doyal lifted the sheet pan rack to its upright position. Later that afternoon, she

completed an accident report form for Mr. Doyal.

Mr. Doyal reported to the emergency department of the Byrd Regional Hospital

on the afternoon of the alleged accident. The department’s records indicate that he

complained of pain to the left shoulder, waist, hip, and lumbar spine and reveal a

diagnosis of contusion to the left shoulder. He also complained of soreness over his

rib cage. Mr. Doyal was instructed not to return to work until seeing his primary care

physician. Although Mr. Doyal treated with various physicians, his complaints of pain continued. Physicians ultimately recommended a diskectomy to alleviate pain

from a herniated lumbar disc and a carpal tunnel release.

Initially, the School Board provided Mr. Doyal with temporary total disability

benefits as well as medical benefits. However, the School Board provided its final

indemnity payment in June 2004. According to Edyce Rivet, the Mor-Tem Risk

Management claims representative assigned to the case, benefits were terminated

after she learned that Mr. Doyal commenced summer employment as the kitchen

manager for a local summer camp. Medical benefits were later terminated. The

lumbar surgery and carpal tunnel release were not provided.

This matter was instituted on August 5, 2004 when the School Board filed a

“Disputed Claim for Compensation” and, in its pre-trial statement, asserted that Mr.

Doyal fraudulently accepted compensation benefits while earning in excess of ninety

percent of his pre-accident wage, provided false statements regarding the occurrence

of the accident, and failed to disclose pre-existing back injuries in his employment

questionnaire and in the history provided to physicians who treated him after the

accident. The School Board sought reimbursement of all indemnity, medical, and

mileage benefits. Mr. Doyal filed his own claim and asserted entitlement to TTD

benefits as well as penalties and attorney’s fees due to the termination of benefits.

The workers’ compensation judge denied the School Board’s forfeiture claims,

reinstated TTD benefits from the date they were last paid, and found Mr. Doyal

entitled to continued medical care, including the recommended back surgery and

carpal tunnel release. The trial court awarded $8,000.00 in penalties and $25,000.00

in attorney’s fees pursuant to La.R.S. 23:1201(I).

The School Board appeals and argues that the workers’ compensation judge

erred in: 1) denying the claim for forfeiture of benefits under La.R.S. 23:1208 and

La.R.S. 23:1208.1; 2) concluding that Mr. Doyal suffered a work-related accident; 3)

2 awarding penalties pursuant to La.R.S. 23:1201(I); and 4) ordering continued medical

care and the lumbar and carpal tunnel surgeries. Mr. Doyal answers the appeal and

asserts that he is due additional penalties for failure to authorize medical benefits. He

also seeks additional attorney’s fees for work performed on appeal.

Discussion

Forfeiture - Louisiana Revised Statutes 23:1208.1

The School Board first contends that the workers’ compensation judge erred

in denying its claim for forfeiture under La.R.S. 23:1208.1 as Mr. Doyal failed to

disclose previous injuries in his employment health questionnaire. The School Board

points to back, hip, shoulder, and leg injuries Mr. Doyal sustained when he fell from

a roof in 1991 and notes that he denied injury to these areas in the employment

questionnaire. At trial, Mr. Doyal explained that he completed the questionnaire with

the assistance of School Board personnel and that he thought the inquiry pertained

to whether he was currently having difficulty or whether he had suffered from the

problems in the recent past.

Louisiana Revised Statutes 23:1208.1, entitled “Employer’s inquiry into

employee’s previous injury claims; forfeiture of benefits[,]” provides:

Nothing in this Title shall prohibit an employer from inquiring about previous injuries, disabilities, or other medical conditions and the employee shall answer truthfully; failure to answer truthfully shall result in the employee’s forfeiture of benefits under this Chapter, provided said failure to answer directly relates to the medical condition for which a claim for benefits is made or affects the employer’s ability to receive reimbursement from the second injury fund. This Section shall not be enforceable unless the written form on which the inquiries about previous medical conditions are made contains a notice advising the employee that his failure to answer truthfully may result in his forfeiture of worker’s compensation benefits under R.S. 23:1208.1. Such notice shall be prominently displayed in bold faced block lettering of no less than ten point type.

(Emphasis added.) In Nabors Drilling USA v. Davis, 03-0136, pp. 5-7 (La. 10/21/03),

857 So.2d 407, 414-15, the supreme court explained:

3 Forfeiture is a harsh remedy; therefore, statutory forfeiture provisions such as LSA-R.S. 23:1208.1 must be strictly construed. Wise v. J.E. Merit Constructors, Inc., 97-0684 (La.1/21/98), 707 So.2d 1214, 1218. By its express terms, LSA-R.S. 23:1208.1 provides for forfeiture under three circumstances. There must be (1) an untruthful statement; (2) prejudice to the employer; and (3) compliance with the notice requirements of the statute. Id., citing Resweber v. Haroil Const. Co., 94-2708, 94-3138 (La.9/5/95), 660 So.2d 7. The employer has the burden of proving each of the elements required by the statute. Wise, 707 So.2d at 1218. The lack of any one of the elements is fatal to the employer’s avoidance of liability under the statute. Id.

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Brian Doyal v. Vernon Parish School Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brian-doyal-v-vernon-parish-school-board-lactapp-2007.