Buggage v. Volks Constructors

945 So. 2d 33, 2005 La.App. 1 Cir. 2002, 2006 La. App. LEXIS 2016, 2006 WL 2773890
CourtLouisiana Court of Appeal
DecidedSeptember 20, 2006
DocketNo. 2005 CA 2002
StatusPublished
Cited by2 cases

This text of 945 So. 2d 33 (Buggage v. Volks Constructors) 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
Buggage v. Volks Constructors, 945 So. 2d 33, 2005 La.App. 1 Cir. 2002, 2006 La. App. LEXIS 2016, 2006 WL 2773890 (La. Ct. App. 2006).

Opinion

HUGHES, J.

| gThis appeal from the Office of Workers’ Compensation presents the issue of whether the workers’ compensation claimant forfeited his rights to workers’ compensation under LSA-R.S. 23:1208.1.

FACTS AND PROCEDURAL HISTORY

On April 15, 2002, Edward Buggage, while in the employ of Volks Constructors (Volks), was thrown from the back of a truck in which he was riding when the driver accelerated the vehicle suddenly. Mr. Buggage contends he suffered head, neck, and back injuries as a result. It was subsequently discovered that Mr. Buggage failed to disclose prior back and neck injuries on his employer’s new hire medical health questionnaire, prompting Volks to deny workers’ compensation benefits.

On January 16, 2004, Mr. Buggage filed a “Disputed Claim for Compensation” with the Office of Workers’ Compensation (OWC). Following a hearing on November 12, 2004, the OWC judge ruled that Mr. Buggage had forfeited his rights to workers’ compensation benefits because he had violated LSA-R.S. 23:1208.1. Mr. Bug-gage appeals this judgment and asserts as error the trial court finding that the defendant met its burden of proof under LSA-R.S. 23:1208.1.

LAW AND ANALYSIS

The workers’ compensation statutes provide two separate anti-fraud forfeiture provisions that employers may use to affirmatively defend against paying a claim. When a falsity has been made on an employer’s medical questionnaire before the accident or injury, LSA-R.S. 23:1208.1 applies. Leonard v. James Industrial Constructors, 2003-0040, p. 4 (La.App. 1 Cir. 5/14/04), 879 So.2d 724, 728, writ denied, 2004-1447 (La.9/24/04), 882 So.2d 1139. When a claimant makes a false statement orjjmisrepresentation during a pending claim for the specific purpose of obtaining workers’ compensation benefits to defraud the system, LSA-R.S. 23:1208 applies. Wise v. J.E. Merit Constructors, Inc., 97-0684, p. 6 (La.1/21/98), 707 So.2d 1214, 1217. It is argued that LSA-R.S. 23:1208.1 applies to the instant case.

In order to encourage the employment of physically handicapped employees who have a permanent partial disability by protecting employers from excess liability for workers’ compensation for disability that may result when a subsequent injury to such an employee “merges” with his preexisting permanent physical disability to cause a greater disability than would have resulted from the subsequent injury alone, the legislature created the Second Injury Fund. An employer who knowingly employs or knowingly retains in his employment an employee who suffers from a permanent partial disability as defined by the applicable statute is entitled to be reimbursed from the fund if that employee incurs a subsequent injury arising out of and in the course of his employment resulting in liability for disability due to the “merger” of the subsequent injury with the preexisting permanent partial disability.1 Nabors Drilling USA v. Davis, 2003-[35]*350136, pp. 4-6 (La.10/21/03), 857 So.2d 407, 413. See also LSA-R.S. 23:1371(A) and LSA-R.S. 23:1378(A)(1).

In order to assist the employer in meeting its statutory burden of establishing that it “knowingly” hired a worker with a preexisting permanent partial disability so as to qualify for reimbursement from the Second Injury [ ¿Fund, LSA-R.S. 23:1208.1 permits the employer to obtain medical information from an employee or job applicant concerning preexisting conditions. The same statute that permits this inquiry also states that the employee’s failure to answer the employer’s inquiry truthfully shall result in the forfeiture of workers’ compensation benefits, provided certain enumerated circumstances are met.2 Nabors Drilling USA v. Davis, 2003-0136 at p. 5, 857 So.2d at 413-14.

Forfeiture is a harsh remedy; therefore, statutory forfeiture provisions such as LSA-R.S. 23:1208.1 must be strictly construed. 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. The employer has the burden of proving each of the elements required by the statute. The lack of any one of the elements is fatal to the employer’s avoidance of liability under the statute. Nabors Drilling USA v. Davis, 2003-0136 at pp. 5-6, 857 So.2d at 414.

Untruthful answers alone do not result in the forfeiture of benefits under LSA-R.S. 23:1208.1. The employer must also prove that it provided the employee with notice comporting with the dictates of the statute. In addition to the notice requirement, the legislature has decided to specifically impose a requirement that the untruthful statement concerning a pri- or injury | Rwill result in forfeiture of benefits only when the false statement causes prejudice to the employer. The provisions of LSA-R.S. 23:1208.1 strike a careful balance that reflect the legislature’s recognition of the harshness of the forfeiture penalty and attempts to ameliorate the harshness of that penalty for the individual who is simply in the position of trying to obtain or maintain gainful employment, while at the same time preserving the goal of the Second Injury Fund, which is to enhance employment opportunities for those who have been previously disabled. Thus, it is not every untruthful statement on a medical history questionnaire that will result in the forfeiture of workers’ compensation benefits for a sub-[36]*36sequent work-related injury. It is only those statements that rise to the level of meeting the statutory proviso of LSA-R.S. 23:1208.1 that will subject the employee to forfeiture. The “prejudice” that must be incurred by the employer for forfeiture to apply is specifically defined by the statute. The untruthful statement must directly relate to the medical condition for which a claim for benefits is made, or it must affect the employer’s ability to receive reimbursement from the Second Injury Fund.3 Nabors Drilling USA v. Davis, 2003-0136 at pp. 6-7, 857 So.2d at 414-15.

In the instant case, a Yolks’ employment questionnaire, signed by Mr. Buggage and dated November 6, 2001, was filed into evidence. At the top of the questionnaire was the following:

InNOTICE TO ALL EMPLOYEES

As you complete the questionnaire (on back), you should be aware that:

FAILURE TO ANSWER TRUTHFULLY MAY RESULT IN FORFEITURE OF YOUR [WORKERS’] COMPENSATION BENEFITS UNDER LA R.S. 23:1208.1.

The following questions were included in the questionnaire:

Have you ever had a disease or disability arising from your occupation?
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Have you ever received workers’ compensation benefits for an injury that occurred?
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Have you ever been rejected for employment, insurance, or military service because of health?
* * *
Have you ever had back trouble or injury to your back, head or neck?
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Do you have any restrictions or limitations upon your physical activities?
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Do you have any other long-term health problems or adverse physical conditions?

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945 So. 2d 33, 2005 La.App. 1 Cir. 2002, 2006 La. App. LEXIS 2016, 2006 WL 2773890, Counsel Stack Legal Research, https://law.counselstack.com/opinion/buggage-v-volks-constructors-lactapp-2006.