Hanks v. Liberty Northwest Ins. Corp.

2002 MT 334, 62 P.3d 710, 313 Mont. 263, 2002 Mont. LEXIS 643
CourtMontana Supreme Court
DecidedDecember 20, 2002
Docket02-298
StatusPublished
Cited by3 cases

This text of 2002 MT 334 (Hanks v. Liberty Northwest Ins. Corp.) is published on Counsel Stack Legal Research, covering Montana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hanks v. Liberty Northwest Ins. Corp., 2002 MT 334, 62 P.3d 710, 313 Mont. 263, 2002 Mont. LEXIS 643 (Mo. 2002).

Opinions

JUSTICE LEAPHART

delivered the Opinion of the Corut.

¶1 Appellant Edna Hanks (Hanks), appeals the Workers’ Compensation Court’s dismissal of her workers’ compensation claim with prejudice. We affirm.

¶2 The sole issue on appeal is whether the Workers’ Compensation Court erred in concluding that Hanks had suffered an injury under the Workers’ Compensation Act and in turn dismissing her occupational disease claim?

Background

¶3 On July 31,1995, Hanks went to work for Partners in Home Care, Incorporated (Partners), as a home-care aide. Her job entailed helping patients with baths and their basic personal care, including helping wheelchair bound patients into and out of their wheelchairs. In [265]*265January 2001, Hanks, then 65 years old, felt a “krik” or “twinge” in her back while helping an Alzheimer’s patient dress. Hanks described the event as causing a “pop-type sound” and “a little pain.” She did not report the incident to her supervisor at the time.

¶4 Prior to the “krik” incident, Hanks had never experienced back problems. Following the “krik” incident, Hanks continued to experience pain. Two or three days after the incident, Hanks began having difficulty getting into and out of her car due to pain radiating into her right leg. On February 8, 2001, Hanks visited Dr. Susan Selbach, her family physician. Dr. Selbach’s office notes for that visit state that Hanks “complains that she has been having some right-sided lower back pain that goes down into her buttocks, has doubled her over on occasion.” When considering possible etiologies of the pain, Dr. Selbach noted only, “She does not remember any recent falls.”

¶5 Despite a trial of physical therapy, Hanks continued to experience low-back pain radiating into her buttocks and leg. On March 13,2001, Hanks underwent an MRI which revealed a left-sided protruding disc at the L4-5 level, as well as significant degenerative changes at that level. Dr. Selbach restricted Hanks to light duty on March 27, 2001, and referred her to Dr. Carter Beck, a neurosurgeon. The next day Hanks told her supervisor about her back pain and the “krik” incident. Hanks’ supervisor filled out a first report that day which indicated that Hanks’ pain was “chronic” and that Hanks was “not sure” of the cause of her pain. Hanks could not recall the date of the “krik” incident, only that it had occurred a couple of months previous, probably sometime in mid-January.

¶6 Hanks was seen by Dr. Beck on April 3, 2001. He reviewed her MRI, which he read as showing “lumbar stenosis at L4-5 where there is bilateral neural foraminal stenosis and subarticular recess stenosis.” On May 9, 2001, he performed a bilateral L4-5 laminotomy and foraminotomy with partial mesial facetectomy.

¶7 Liberty, the insurance provider for Partners, denied Hanks benefits on account of her failure to report the “krik” incident to her employer within 30 days of its occurrence as required by the Workers’ Compensation Act.

¶8 On August 27, 2001, at the request of the Department of Labor and Industry, Dr. Randale C. Sechrest, an orthopedic surgeon, examined Hanks. Dr. Sechrest reported that Hanks suffered from “long-standing degenerative changes in the lumbar spine” which were rendered symptomatic in J anuary or February of2001, and most likely were aggravated by her activity at work. In his report, Dr. Sechrest [266]*266stated that Hanks’ need for surgery “arose from her underlying degenerative disease” and “spinal stenosis secondary to [her] longstanding degenerative” disease. In his deposition, he reiterated that Hanks had long-standing and extensive degenerative back disease, but also added that her condition was aggravated and made symptomatic by the “krik” incident.

¶9 The Workers’ Compensation Court granted Hanks’ petition for an emergency trial, which was conducted on December 10, 2001. On March 22, 2002, it issued a judgment dismissing Hanks’ claim with prejudice based on its findings that although Hanks had suffered an injury under the Workers’ Compensation Act, she had failed to comply with the Act’s 30-day notice requirement. Hanks appeals from this judgment. We affirm.

Discussion

¶10 Did the Workers’ Compensation Court err in concluding that Hanks had suffered an injury under the Workers’ Compensation Act and in turn denying her occupational disease claim?

¶11 A claimant has the burden of proof that he or she is entitled to benefits under the Workers’ Compensation Act. King v. TTC Illinois, Inc., 2000 MT 260, ¶ 11, 301 Mont. 527, ¶ 11, 11 P.3d 1199, ¶ 11. This Court reviews the Workers’ Compensation Court’s findings to determine whether they are supported by substantial credible evidence and reviews its conclusions of law to determine whether they are correct. See Schimmel v. Montana Uninsured Employers Fund, 2001 MT 280, ¶ 5, 307 Mont. 344, ¶ 5, 38 P.3d 788, ¶ 5.

¶12 Workers’ compensation benefits are determined by the statutes in effect as of the date of injury. Buckman v. Montana Deaconess Hosp. (1986), 224 Mont. 318, 321, 730 P.2d 380, 382. The 1999 version of the Act applies since it was in effect at the time of Hanks’ “krik” incident. Accordingly, all statutory references hereinafter will be to the 1999 version of the Act unless otherwise indicated.

¶13 The 30-day notice requirement of the Workers’ Compensation Act is located at § 39-71-603, MCA, and provides as follows:

A claim to recover benefits under the Workers’ Compensation Act for injuries not resulting in death may not be considered compensable unless, within 30 days after the occurrence of the accident that is claimed to have caused the injury, notice of the time and place where the accident occurred and the nature of the injury is given to the employer or the employer’s insurer by the injured employee or someone on the employee’s behalf.

[267]*267This provision of the Act is mandatory, and compliance with the notice requirement is indispensable to maintaining a claim for compensation. Reil v. Billings Processors, Inc. (1987), 229 Mont. 305, 309-10, 746 P.2d 617, 619. The purpose of the notice requirement is to enable the employer to protect itself by prompt investigation of the claimed accident and prompt treatment of the injury to minimize its effect. Larson v. Barry Smith Logging, Inc. (1994), 267 Mont. 444, 448, 884 P.2d 786, 788-89; Bender v. Roundup Mining Co. (1960), 138 Mont. 306, 313, 356 P.2d 469, 473.

¶14 Because it is undisputed that Hanks failed to report the “krik” incident to Partners within 30 days of its occurrence, the threshold question in this case is whether the “krik” incident qualifies as an “injury” under the Workers’ Compensation Act. If it does, Hanks’ failure to meet the mandatory requirements of the Act, specifically her failure to timely notify her employer, bars her from receiving workers’ compensation benefits.

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

Related

SIEBKEN v. Liberty Mutual Insurance Co.
2008 MT 353 (Montana Supreme Court, 2008)
Thompson v. Liberty Nw Ins.
2004 MT 166N (Montana Supreme Court, 2004)
Hanks v. Liberty Northwest Ins. Corp.
2002 MT 334 (Montana Supreme Court, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
2002 MT 334, 62 P.3d 710, 313 Mont. 263, 2002 Mont. LEXIS 643, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hanks-v-liberty-northwest-ins-corp-mont-2002.