Darrell Slaughter v. City of Fayetteville and Arkansas Municipal League

2022 Ark. App. 139, 643 S.W.3d 809
CourtCourt of Appeals of Arkansas
DecidedMarch 30, 2022
StatusPublished

This text of 2022 Ark. App. 139 (Darrell Slaughter v. City of Fayetteville and Arkansas Municipal League) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Darrell Slaughter v. City of Fayetteville and Arkansas Municipal League, 2022 Ark. App. 139, 643 S.W.3d 809 (Ark. Ct. App. 2022).

Opinion

Cite as 2022 Ark. App. 139 ARKANSAS COURT OF APPEALS DIVISIONS I AND II No. CV-21-104

Opinion Delivered March 30, 2022 DARRELL SLAUGHTER APPELLANT APPEAL FROM THE ARKANSAS V. WORKERS’ COMPENSATION COMMISSION CITY OF FAYETTEVILLE AND [NO. F607819] ARKANSAS MUNICIPAL LEAGUE

APPELLEES AFFIRMED

N. MARK KLAPPENBACH, Judge

This is an appeal from a decision of the Arkansas Workers’ Compensation

Commission denying a claim for additional medical benefits related to Darrell Slaughter’s

compensable spine injuries. The Commission found that Slaughter’s claim was barred by the

applicable one-year statute of limitations. Slaughter argues that the Commission’s decision

is not supported by substantial evidence and constitutes an error of law. We affirm.

Slaughter was working as a Fayetteville police patrol officer when, on March 10, 2004,

the motorcycle he was driving was struck by a vehicle. He suffered an impact injury to his

mid-back, a whiplash injury to his neck, and various abrasions. His workers’- compensation

claim was accepted as compensable, specifically including injuries to his spine at C3/4,

C6/T1, and T1/2. He received medical and disability benefits.1 His treatments included

1 The employer paid indemnity benefits until October 2009. medication, imaging studies, clinic visits, neurology testing, physical therapy, spinal

injections, one spinal surgery in 2006, and one spinal surgery in 2009. Slaughter continued

to work until retiring in 2010, but his employer continued to pay for his related continuing

medical treatment for years.

Relevant to this appeal, Slaughter received facet-joint injections into his thoracic

spine on November 2, 2016, for the purposes of relieving back pain.2 Slaughter called the

doctor’s office in October 2017 to obtain another appointment for injections, but he could

not get an appointment any sooner than December 7, 2017. He asked to be put on a

cancellation list in case an earlier appointment became available, but he was never called.

Slaughter continued to see his medical caregivers regarding his spine problems in

2018 and 2019, which Fayetteville’s workers’-compensation insurance carrier continued to

pay. In mid-July 2019, however, at a clinic visit, Slaughter was told that the insurance carrier

would no longer pay for Slaughter’s medical care related to his compensable injuries.3 In

response, Slaughter filed a claim for additional medical benefits on July 29, 2019. In

resistance to Slaughter’s claim, Fayetteville raised a statute-of-limitations defense and

contended that there was a gap of more than one year in medical treatment between the

2 On December 15, 2016, the workers’-compensation insurance carrier issued a check to pay for the November 2016 injection. 3 Despite this announcement, the insurance carrier continued to pay Slaughter’s medical expenses until April 2020. The additional-medical-benefits issue was litigated before the workers’ compensation administrative law judge (ALJ) in June 2020. In January 2021, the Commission affirmed and adopted the ALJ’s decision, leading to this appeal. 2 November 2, 2016, and December 7, 2017 facet-joint injections. Fayetteville argued that

because the period between those two medical treatments exceeded one year, the statute of

limitations barred any further medical treatment being the responsibility of the employer.

Fayetteville also contended that any medical care that was provided after the statute of

limitations had run did not revive the claim. Slaughter asserted that the insurance carrier

did not actually pay for the November 2016 injections until mid-December 2016, and less

than a year passed before he was again given spinal injections on December 7, 2017.

Slaughter asserted, in the alternative, that the insurance carrier voluntarily continued to pay

for his medical treatments long after those injections, so the statute of limitations was

renewed or revived by the voluntary continued payments, which made his July 2019 claim

timely.

The Commission agreed with Fayetteville’s argument and determined that the

relevant dates were the dates medical services were actually provided to Slaughter in 2016

and 2017, not the date those services were paid for. The Commission also found that the

continued provision of medical care did not revive Slaughter’s claim because the statute of

limitations had already run in 2017. Slaughter appeals.

While we generally affirm workers’-compensation appeals if the decision is supported

by substantial evidence, we review questions of law from the Commission de novo. When

the Commission denies benefits because a claimant has failed to meet his or her burden of

proof, the substantial-evidence standard of review requires that we affirm if the

Commission’s decision displays a substantial basis for the denial of relief. White Cnty. Judge

3 v. Menser, 2020 Ark. 140, 597 S.W.3d 640. However, this appeal concerns the construction

and application of Arkansas Code Annotated section 11-9-702(b)(1) (Repl. 2012). The

correct interpretation and application of an Arkansas statute is a question of law. Wynne v.

Liberty Trailer, 2021 Ark. App. 374, 636 S.W.3d 348. This court decides what a statute

means. Id. When we interpret the workers’-compensation statutes, we must strictly construe

them. Id. Strict construction requires that nothing be taken as intended that is not clearly

expressed; we are required to use the plain meaning of the language employed. Id.

The time limitations for requesting additional workers’-compensation benefits are set

forth in Arkansas Code Annotated section 11-9-702, which provides, in pertinent part,

(b) TIME FOR FILING ADDITIONAL COMPENSATION.

(1) In cases in which any compensation, including disability or medical, has been paid on account of injury, a claim for additional compensation shall be barred unless filed with the commission within one (1) year from the date of the last payment of compensation or two (2) years from the date of the injury, whichever is greater.

(Emphasis added.) It is a claimant’s burden to prove that he acted within the time allowed

for filing a claim for additional compensation. Kent v. Single Source Transp., Inc., 103 Ark.

App. 151, 287 S.W.3d 619 (2008). The running of the statute of limitations is largely a

question of fact. Farris v. Express Servs., Inc., 2019 Ark. 141, 572 S.W.3d 863.

Slaughter raises three arguments on appeal asserting that the Commission erred in

finding: (1) that more than one year had passed between the provision of medical treatment

in 2016 and 2017, which meant that the one-year statute of limitations barred any claim for

additional medical benefits; (2) that the employer’s voluntary provision of medical benefits

4 from and after 2017 did not revive Slaughter’s claim; and (3) that the employer’s defense was

not barred by the doctrine of estoppel. Slaughter contends that the Commission’s decision

is not supported by substantial evidence, constitutes legal error, and must be reversed.

Slaughter has failed to present reversible error.

Slaughter first contends that there was no greater-than-one-year gap in workers’-

compensation benefits because the employer paid the bill for the November 2016 spinal

injections in mid-December 2016, which was within a year of his next spinal injections in

early December 2017.

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Related

Kent v. Single Source Transportation, Inc.
287 S.W.3d 619 (Court of Appeals of Arkansas, 2008)
Woodard v. ITT Higbie Manufacturing Co.
609 S.W.2d 115 (Court of Appeals of Arkansas, 1980)
Osborne v. Bekaert Corp.
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Plante v. Tyson Foods, Inc.
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Heflin v. Pepsi Cola Bottling Co.
424 S.W.2d 365 (Supreme Court of Arkansas, 1968)
Stewart v. Arkansas Glass Container
2010 Ark. 198 (Supreme Court of Arkansas, 2010)
Miller v. Enders
2013 Ark. 23 (Supreme Court of Arkansas, 2013)
Kirk v. Cent. States Mfg. Inc.
540 S.W.3d 714 (Court of Appeals of Arkansas, 2018)
Farris v. Express Servs., Inc.
2019 Ark. 141 (Supreme Court of Arkansas, 2019)
Cheshire v. Foam Molding Co.
822 S.W.2d 412 (Court of Appeals of Arkansas, 1992)
Lawhon Farm Services v. Brown
984 S.W.2d 1 (Supreme Court of Arkansas, 1998)
Lavaca School District and Arkansas School Boards Association v. Pat Hatfield
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Terry Wynne v. Liberty Trailer and Death and Permanent Total Disability Trust Fund
2021 Ark. App. 374 (Court of Appeals of Arkansas, 2021)

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2022 Ark. App. 139, 643 S.W.3d 809, Counsel Stack Legal Research, https://law.counselstack.com/opinion/darrell-slaughter-v-city-of-fayetteville-and-arkansas-municipal-league-arkctapp-2022.