Falline v. GNLV CORP.

823 P.2d 888, 107 Nev. 1004, 1991 WL 278883
CourtNevada Supreme Court
DecidedDecember 30, 1991
Docket20549
StatusPublished
Cited by97 cases

This text of 823 P.2d 888 (Falline v. GNLV CORP.) is published on Counsel Stack Legal Research, covering Nevada Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Falline v. GNLV CORP., 823 P.2d 888, 107 Nev. 1004, 1991 WL 278883 (Neb. 1991).

Opinions

[1006]*1006OPINION

By the Court,

Steffen, J.:

Appellants Norman and Sharon Falline sought to maintain common law or private causes of action against respondents GNLV Corporation (Golden Nugget), a self-insured employer, and Gibbens Company, Inc. (Gibbens), the administrator of Golden Nugget’s self-insured plan. The causes of action included claims for negligence and bad faith in the processing and payment of claims, intentional and negligent infliction of emotional distress, unfair insurance practices, and other claims which will not be specifically addressed in this opinion. We conclude that the district court erred in dismissing two of appellants’ claims, and therefore reverse and remand as to those claims.1

At the age of twenty-five, appellant Norman Falline (Falline) injured his back while working as a maintenance laborer at the Golden Nugget. The injury eventually required surgery. Approximately ten weeks after surgery, Falline experienced severe pain [1007]*1007in his lower back as he arose from a sitting position. An examining physician determined that there was no new injury and concluded that Falline’s initial surgery left him prone to reinjury. The physician recommended treatment for the acute problem and determined that Falline was temporarily totally disabled. Based upon the physician’s findings and recommendations, Falline sought to have his claim reopened. Despite the doctor’s report, Gibbens and the Golden Nugget denied further liability, stating that Falline had suffered an intervening injury.

Falline appealed respondents’ rejection of his claim to a hearing otficer, who ruled in favor of reopening the claim and paying benefits. Respondents thereafter appealed to an appeals officer who also ruled in Falline’s favor. Subsequently, respondents sought judicial review, but the district court upheld the decision of the appeals officer and ordered the insurer to pay both accident and compensation benefits. Respondents’ appeal to this court was dismissed by order filed on June 26, 1986. Stay orders sought by respondents from the district court and this court were also denied.

After Falline was released to return to work, his employment was terminated about three months later. Rehabilitation benefits were subsequently refused by respondents, despite a hearing officer twice ruling that Falline was entitled to such benefits.

Appellants first contend that the district court erred in dismissing their cause of action for the negligent or bad faith delay in the payment of workmen’s compensation benefits. We agree. In our recent opinion in Northern Nev. Ass’n of Injured Workers v. Nevada State Indus. Ins. Sys., 107 Nev. 108, 807 P.2d 728 (1991), we reaffirmed our ruling in Rush v. Nevada Industrial Commission, 94 Nev. 403, 580 P.2d 952 (1978), holding that a claimant could maintain a cause of action against the State Industrial Insurance System (SIIS) under a common law negligence theory because SIIS was a third party separate and apart from the employer. We now conclude that there is no rational basis for permitting such an action against SIIS, which is funded by contributions from employers, and denying the same right of action against administrators of self-insured plans which are also funded by employers. In both instances, “administrators” are obligated to promptly, fairly, and in good faith, process and pay where warranted, compensation benefits to injured workers. Moreover, it makes no difference whether a self-insured plan is administered by the self-insured employer or an agent employed for that purpose. Although Nevada law (NRS 616.2947) imposes liability on a self-insured employer for penalties resulting from the derelictions of the administrator/agent, there is no sound reason why [1008]*1008a self-insured employer should not be liable for damages resulting from the negligent or bad faith administration of the self-insured plan by the administrator/agent. There are cogent reasons for concluding that such liability would not constitute an erosion of the employer’s immunity from common law liability for work-related injuries under NRS 616.272(2). First, the basis for liability is not the industrial injury upon which the workmen’s compensation claim is based, but rather the negligent or bad faith failure or refusal to timely pay the compensation due. Second, the self-insured employer who relies on a fair, efficient, and lawful administration of the self-insured plan by an administrator/agent, and suffers damage by the latter’s breach of duty, may seek indemnification from the administrator/agent for such damages assessed against the self-insured employer. See, e.g., Salt Lake City School District v. Galbraith & Green, Inc., 740 P.2d 284 (Utah Ct.App. 1987). Third, it would unfairly discriminate against employees of a self-insured employer to disallow an action for damages resulting from the negligent or bad faith failure or refusal to timely pay compensation entitlements while allowing a similar action against SHS by employees of employers who are not self-insured.2

Although Falline properly exhausted his administrative remedies, the record reflects that while administrative and judicial remedies were pursued, he was denied compensation benefits during two intervals that were each approximately six months in duration. During these periods, Falline claims that he and his wife were forced to borrow money, sell their automobile and request the help of relatives.

Our case law strongly emphasizes that one of the obligations of a self-insurer “is the prompt payment of benefits, and if payment is determined to be unwarranted, the self-insurer must seek reimbursement of benefits it paid.” Imperial Palace v. Dawson, 102 Nev. 88, 92, 715 P.2d 1318, 1320 (1986) (quoting Dep’t Ind. Relations v. Circus Circus, 101 Nev. 405, 411-12, 705 P.2d 645, 649 (1985)). Under our rulings, respondents’ vexatious and dilatory withholding of Falline’s compensation cannot be condoned. Nevertheless, there is another consideration that must be [1009]*1009addressed in determining whether Falline has a right of action against respondents.

Our ruling in Northern Nev. Ass’n of Injured Workers, supra, recognized that under Nevada law, NRS 41.032, the liability of SUS and its employees for negligent acts is limited to acts that are of an operational, rather than discretionary, nature. Although statutory immunity for discretionary acts is accorded only to governmental agencies and employees, we have determined that a denial of such immunity to self-insured employers and their administrators/agents would constitute an unwarranted, discriminatory source of liability against the latter.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
823 P.2d 888, 107 Nev. 1004, 1991 WL 278883, Counsel Stack Legal Research, https://law.counselstack.com/opinion/falline-v-gnlv-corp-nev-1991.