Commercial Union Ins. Co. v. Maine Employers Mut. Ins. Co.

CourtSuperior Court of Maine
DecidedJune 28, 2001
DocketKENap-00-39
StatusUnpublished

This text of Commercial Union Ins. Co. v. Maine Employers Mut. Ins. Co. (Commercial Union Ins. Co. v. Maine Employers Mut. Ins. Co.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commercial Union Ins. Co. v. Maine Employers Mut. Ins. Co., (Me. Super. Ct. 2001).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION

KENNEBEC, ss. DOCKET NO. Ap | ok, j ; 7h 3 } oe

SU 4 | :

COMMERCIAL UNION

INSURANCE COMPANY,

a/k/a COMMERCIAL UNION

YORK INSURANCE

COMPANY, et al.,

Petitioners Vv. DECISION AND ORDER

MAINE EMPLOYERS' MUTUAL INSURANCE COMPANY, et al.,

Respondents

I. Introduction.

This matter is before the court on the petition of Commercial Union Insurance

Company, a/k/a Commercial Union York Insurance Company (CU), via M.R. Civ. P.

80C. It seeks a review of final agency action in the form of a decision by an arbitrator

appointed by the Bureau of Insurance which apportioned responsibility for workers’

compensation payments between it and the respondent, Maine Employers’ Mutual

Insurance Co. (MEMIC). An administrative appeal under M.R. Civ. P. 80C to this court

is the appropriate procedure to be followed when challenging such a decision.

Livingstone v. A-R Cable Services of Maine, 2000 ME 18, J 9, 746 A.2d 901, 904.

The parties have filed a record, their briefs, and oral argument was heard;

accordingly, this matter is in order for disposition. II. History.

Before addressing the merits of the parties’ respective positions in this case, a brief review of its history must be recounted.

Bruce Agren worked for Allen Rogers Limited doing business in Maine under the name "Dirigo Dowels." He was injured on the job on April 16, 1993. At the time his employer was insured for workers’ compensation coverage by CU. On November 1, 1993, he was injured again, but the employer had coverage through MEMIC at that time.

On August 22, 1996, a mediator conducted a phone mediation on the issues of AWW (average weekly wage), work-relatedness, apportionment and fringe benefits. All parties participated in this process. As a result, the mediator found that the parties agreed on all issues, except fringe benefits. Among these agreements was the provision, relevant to the dispute here, that, "CU will pay 30% and MEMIC will pay 70%."

On April 8, 1998, MEMIC demanded that an arbitrator be appointed pursuant to 39-A M.R.S.A. § 354(3) (1993) to "revise[d] and finalize[d]" the earlier apportionment agreement "informally entered into" so that it may have "a proper apportionment finding.” The next day, April 9, 1998, the Bureau of Insurance, through its senior staff attorney, appointed Jonathan Reitman, Esq. as arbitrator. On April 23, 1998, CU objected to the appointment, claiming that the matters the arbitrator was to decide had

already been decided by way of the apportionment agreement that was formalized on

1 Neither party contests that this sentence refers to an agreement between them as to apportionment of responsibility for workers’ compensation payments to Mr. Agren.

2 August 22, 1996, so that res judicata applied because the agreement had the force of a Workers' Compensation Board (Board) decree.

Near in time to these developments, namely on April 9, 1998, and April 17, 1998, three related pleadings were filed with the Board: on the former date, MEMIC's petition to determine average weekly wage, and on the latter date, Mr. Agren's petition for award as to CU, and his petition for award as to MEMIC. On January 21, 1999, MEMIC also filed a petition to determine extent of permanent injury.

On December 7, 1999, the Board's hearing officer (HO) granted all the petitions pending before her. As to apportionment between the two insurers for responsibility for payments to the employee, the HO made note of the August 22, 1996 agreement and the circumstance that none of the pleadings before her provided a procedural vehicle to adjust this allocation and, further, that there was no persuasive evidence "that a different allocation would be more appropriate."

On May 15, 2000, the appointed arbitrator issued his decision, in which he determined that the August, 1996 mediation agreement was not binding on the parties “for all time,” that the Board had not reached the question of apportionment, and, in the end, agreed with MEMIC's proposal that apportionment between the parties for

payment of workers’ compensation benefits should be a 50/50 split.3

2 Apparently the delay between the arbitrator's appointment and his decision was occasioned by a stay pending action by the Board on the petitions before its HO.

3 CU also proposed the 50/50 apportionment favored by MEMIC, but asserts it did so only as an alternative position if the arbitrator rejected the 30/70 division it supported. Apparently the rationale for this alternative position was explained in CU's brief presented to the arbitrator which was not included in the record before this court. III. Discussion.

The heart of the parties’ dispute in this matter is the effect of the mediated agreement as to apportionment between them of responsibility for workers’ compensation payments to the injured employee. The petitioner, CU, argues that the agreement is binding and final so that the arbitrator should not have been appointed by the Bureau of Insurance and that he erred in changing the apportionment responsibility between these two insurers. The respondent, MEMIC, asserts that the mediated agreement was temporary in nature and that the exclusive means of resolving apportionment disputes is by arbitration as required by statute.

In resolving this debate, it is necessary to examine the two statutes which have been applied by the Board and the Bureau of Insurance before this case made its way to this court. The first of these is 39-A M.R.S.A. § 313 (2000). It provides for mediation of disputes among employee, employer, and insurer with the objective of reaching agreement among them. The second is 39-A M.R.S.A. § 354(3) (1993). It governs the resolution of disputes between insurers as to apportionment responsibility when two or more insurers may be responsible for an injured worker's compensation.

The first of these statutes, 39-A M.R.S.A. § 313 (2000), mandates referral by the Board to mediation “upon filing a notice of controversy or other indication of controversy.” Id. section 313(1) (2000). The mediator is then to determine the nature of the controversy and attempt to resolve it. Id. section 313(2) (2000). At the conclusion of mediation, the mediator is to file a written report with the Board listing the legal and factual issues in dispute and those that are agreed on. Id. section 313(3) (2000). Once

done, all the parties and the mediator are to sign the report. Id. Any party, including an insurer, participating in this mediation process must have authority to make decisions regarding the employee's claim. Id. section 313(5) (2000).

The parties in the case at bar and the injured employee participated in this statutorily authorized mediation process and agreed to a resolution of all but one controversy among them, including apportionment between these two insurers. The agreement was signed and, apparently, sent to the Board as the statute requires. In the court's view, this process finally resolved any apportionment issue and the agreement ~ entered into is binding on the parties.

The purpose of section 313 is obviously the same as the purpose of any mediation of a controversy or dispute, that is, to resolve quickly, finally, and inexpensively the issues pending among parties. Indeed, the Law Court has found that the legislative history of section 313 ". . . suggests that the Legislature intended mediation to replace litigation whenever possible." Bureau v. Staffing Network, Inc., 678 A.2d 583, 590 (Me. 1996).

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Related

Rosetti v. Land Reclamation
1997 ME 197 (Supreme Judicial Court of Maine, 1997)
Bureau v. Staffing Network, Inc.
678 A.2d 583 (Supreme Judicial Court of Maine, 1996)
Livingstone v. A-R Cable Services of Maine
2000 ME 18 (Supreme Judicial Court of Maine, 2000)

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Commercial Union Ins. Co. v. Maine Employers Mut. Ins. Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commercial-union-ins-co-v-maine-employers-mut-ins-co-mesuperct-2001.