Hartford Underwriters Insurance Company/Richard Hafley v. Richard Hafley/Hartford Underwriters Insurance Company

CourtCourt of Appeals of Texas
DecidedOctober 10, 2002
Docket03-02-00107-CV
StatusPublished

This text of Hartford Underwriters Insurance Company/Richard Hafley v. Richard Hafley/Hartford Underwriters Insurance Company (Hartford Underwriters Insurance Company/Richard Hafley v. Richard Hafley/Hartford Underwriters Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hartford Underwriters Insurance Company/Richard Hafley v. Richard Hafley/Hartford Underwriters Insurance Company, (Tex. Ct. App. 2002).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN



NO. 03-02-00107-CV

Hartford Underwriters Insurance Company/Richard Hafley, Appellants



v.



Richard Hafley/Hartford Underwriters Insurance Company, Appellees



FROM THE DISTRICT COURT OF COMAL COUNTY, 274TH JUDICIAL DISTRICT

NO. C-97-400C, HONORABLE CHARLES RAMSAY, JUDGE PRESIDING

This is a worker's compensation case. Hartford Underwriters Insurance Company ("Hartford") challenges an award of Supplemental Income Benefits made by the Worker's Compensation Commission ("the Commission") to Richard A. Hafley ("Hafley"). See Tex. Lab. Code Ann. §§ 408.142, .147(c) (West 1996 & Supp. 2002). In a modified trial de novo, the district court affirmed the award and awarded attorney's fees to Hafley. See id. §§ 410.251, .252 (West 1996). Hartford argues that: (1) the Commission improperly calculated Hafley's income from self-employment based on net, rather than gross, income; (2) the evidence before the district court was insufficient to support a benefits award; and (3) Hafley did not "prevail" on any issue within the scope of the statute and was not entitled to attorney's fees. Hafley has also appealed, challenging the district court's jurisdiction to review the Commission's decision. We will affirm.

BACKGROUND

In 1992, the Commission awarded Hafley disability benefits based on a work-related back injury. By 1994, he had reached maximum recovery, with a seventeen percent impairment rating. This impairment rating made him eligible for Supplemental Income Benefits ("SIBs") so long as his wages remained less than eighty percent of his pre-injury wages. Id. § 408.412. Like other worker's compensation benefits, SIBs are administered through an administrative process that is meant to ensure quick disbursement of benefits and decrease the need to litigate relatively small claims. See generally id. §§ 408.081-.162 (West 1996 & Supp. 2002) (hereinafter "the Act"); Texas Workers' Comp. Comm'n v. Garcia, 893 S.W.2d 504, 513, 521 (Tex. 1995).

SIBs require a comparison between an injured employee's pre-injury wages and his wages after reaching maximum recovery. Tex. Lab. Code Ann. § 408.412(b). Although Hafley had been a wage-earning employee at the time he was injured, he was self-employed during the relevant benefits period. Because Hafley did not receive "wages" from a third-party employer, the hearing officer calculated his wages as the difference between his total self-employment income and his business expenses. Hartford challenged the award, and an appeals board affirmed. Hartford then filed an appeal in the Comal County District Court. After a bench trial, the district court affirmed the Commission's decision and awarded attorney's fees.

In this appeal, Hartford complains that Hafley's income should have been calculated on the basis of his gross, rather than net, self-employment income. Hartford also challenges the award of attorney's fees, claiming that Hafley has not prevailed on any issue within the meaning of the Act's fee provision. Finally, Hartford challenges the legal and factual sufficiency of the district court's findings.

Hafley also appeals, challenging the district court's refusal to dismiss the cause for want of jurisdiction. Hafley argues that, because he is a resident of Guadalupe County, rather than Comal County, the district court could not exercise jurisdiction under the Act's provisions. We will consider the jurisdictional issue first.



DISCUSSION

Jurisdiction and Venue

Hafley's original application for benefits listed his street address as being in New Braunfels and Comal County. Based on this information, Hartford filed its appeal in the District Court of Comal County. Hafley's street address, however, is in an area of New Braunfels that actually lies in Guadalupe County. The Act requires that an appeal be filed in "the county where the employee resided at the time of the injury." Id. § 410.252(b)(1). Thus, Hartford did not file in Hafley's county of residence and failed to satisfy section 410.252(b)(1). Hafley contends that this failure is jurisdictional and asks us to dismiss the appeal and reinstate the Commission's order.

The relevant section of the Act provides as follows:



Time for Filing Petition; Venue



(a) A party may seek judicial review by filing suit not later than the 40th day after the date on which the decision of the appeals panel was filed with the division.



(b) The party bringing suit to appeal the decision must file a petition with the appropriate court in:

(1) the county where the employee resided at the time of the injury or death if the employee is deceased; or



(2) in the case of an occupational disease, in the county where the employee resided on the date disability began or any county agreed to by the parties.



Tex. Lab. Code Ann. § 410.252. Relying on Dubai Petroleum Co. v. Kazi, 12 S.W.3d 71 (Tex. 2000), Hafley argues that the venue provisions of section 410.252 are jurisdictional and, therefore, Hartford's petition must be dismissed. He takes the position that the venue requirement is a substantive limitation on the power of the district court to exercise appellate power over the Commission. Hartford responds that the section, as shown by its heading, is merely a venue statute and failure to comply with it does not deprive the district court of jurisdiction.

In Dubai, the supreme court reversed the long-standing doctrine of Mingus v. Wadley, 115 Tex. 551, 285 S.W. 1084 (Tex. 1926), which held that the technical requirements of a statutory cause of action, created in derogation of the common law, are jurisdictional. Mingus, like the case at hand, involved a challenge to a worker's compensation award. The then-current statute provided several statutory prerequisites to appeal from the Industrial Accident Board's determinations, including a venue requirement that suit be brought "in the county where the injury occurred." Mingus, 285 S.W. at 1087-88. The Mingus court reasoned that, because worker's compensation is statutory, an appeal from a compensation award must be dismissed if brought in any county other than that where the injury occurred. Id.

Dubai rejected Mingus "to the extent that it characterized the plaintiff's failure to establish a statutory prerequisite as jurisdictional." Dubai, 12 S.W.3d at 74.

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Bluebook (online)
Hartford Underwriters Insurance Company/Richard Hafley v. Richard Hafley/Hartford Underwriters Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hartford-underwriters-insurance-companyrichard-haf-texapp-2002.