Department Of Labor & Industries, V. George Higgins, Sr.

CourtCourt of Appeals of Washington
DecidedMarch 8, 2022
Docket55148-9
StatusPublished

This text of Department Of Labor & Industries, V. George Higgins, Sr. (Department Of Labor & Industries, V. George Higgins, Sr.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Department Of Labor & Industries, V. George Higgins, Sr., (Wash. Ct. App. 2022).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. Filed Washington State Court of Appeals Division Two

March 8, 2022

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II WASHINGTON STATE DEPARTMENT OF No. 55148-9-II LABOR AND INDUSTRIES,

Respondent,

v.

GEORGE H. HIGGINGS SR., PUBLISHED OPINION

Appellant.

VELJACIC, J. — George Higgins Sr. was injured in 1989 while working as an electrician’s

helper. He received workers’ compensation benefits, including disability and medical benefits. In

1992, his condition became fixed and the Department of Labor and Industries (Department)

awarded him category 2 partial permanent disability and closed his claim. He attempted to reopen

his claim in 1993 and 1994, but failed to provide sufficient medical evidence of aggravation. In

2005, over seven years after his claim was closed, he again sought to reopen it. He sought medical

and disability benefits in the form of time loss compensation or a pension. The Department

Director eventually granted him medical benefits and increased his disability award, but did not

allow any additional time loss compensation.

Higgins appealed to the Board of Industrial Insurance Appeals (Board), arguing he was

entitled to time loss compensation. He also argued that the Board should review his appeal under

a preponderance of the evidence standard. The Board agreed that the preponderance of the

evidence standard was the correct standard of review. The Department appealed that decision to For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. 55148-9-II

the superior court. The court ruled that the Board should have used the abuse of discretion standard

in evaluating the Director’s failure to award additional time loss compensation. Higgins appeals

the court’s standard of review ruling.

We agree with the Department and affirm the superior court’s ruling that the correct

standard to review the Director’s decision is abuse of discretion, remanding this matter to the Board

for proceedings consistent with this opinion.

FACTS

In 1989, Higgins suffered an industrial injury while working as an electrician’s helper.

That claim was closed in 1992 with a category 2 partial permanent disability award. Higgins

attempted to reopen his claim in 1993 and 1994, but the Department denied both because there

was no “objective medical worsening.” AR at 176-77.

In 2001, Higgins opened an automotive shop, but was forced to close it in 2003 because he

was unable to participate in the business due to his industrial injury. In 2005, more than seven

years after his claim was closed, Higgins again sought to reopen his claim to receive time loss

compensation or a pension. At first, the Director denied his reopening request, but eventually

awarded additional medical benefits while denying Higgins’s disability benefit request. Later, the

Director reconsidered the denial and eventually awarded category 4 partial permanent disability

benefits. The Director decided not to award time loss compensation, stating,

I am not exercising my discretionary authority to find you eligible for time- loss compensation because you stopped working in 2003 and there is no contemporaneous medical [sic] to support that you stopped working due to your industrial injury. However, I am exercising my discretionary authority to find you eligible for permanent partial disability benefits in the interest of equity and good conscience, because you had a significant increase in permanent impairment of your lumbar condition.

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. 55148-9-II

Administrative Record (AR) at 135.

Higgins appealed the Director’s decision to the Board seeking time loss compensation or a

pension. The Board concluded that under Cascade Valley Hospital v. Statch, 152 Wn. App. 502,

508, 215 P.3d 1043 (2009), the correct standard of review of the Director’s decision is

preponderance of the evidence. Accordingly, the Board reversed the Director’s decision and

remanded back to the Department to pay time loss compensation.1 One Board member dissented.

The Department appealed the Board’s decision to the superior court, arguing that the Board

erred in using a preponderance of the evidence standard and that the correct standard was abuse of

discretion. The superior court ruled that based on the language of RCW 51.32.160, the Director

has discretion to decide whether to reopen a claim and the Board should have used an abuse of

discretion standard to review the Director’s decision. The court remanded to the Board to apply

the correct standard. Higgins appeals the superior court’s ruling.

ANALYSIS

I. STANDARD OF REVIEW AND LEGAL PRINCIPLES

A. Statutory Interpretation

The primary goal of statutory construction is to determine and give effect to the

legislature’s intent. SEIU Healthcare 775NW v. Dep’t of Soc. & Health Servs., 193 Wn. App. 377,

398, 377 P.3d 214 (2016). To determine legislative intent, we examine the plain language of the

statute, the context of the statute in which the provision is found, and related statutes. SEIU, 193

Wn. App. at 398. “‘[I]f the statute’s meaning is plain on its face, then the court must give effect

1 In a subsequent case concerning the Director’s decisions under RCW 51.32.160, the Board decided that the preponderance of the evidence standard was incorrect and adopted the abuse of discretion standard, with one member dissenting. In re: David A. Platzer, No. 18 26897 (Wash. Bd. of Indus. Ins.

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