Hincks v. Robert Mitchell Co.

1999 ME 172, 740 A.2d 992, 1999 Me. LEXIS 181
CourtSupreme Judicial Court of Maine
DecidedNovember 24, 1999
StatusPublished
Cited by8 cases

This text of 1999 ME 172 (Hincks v. Robert Mitchell Co.) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hincks v. Robert Mitchell Co., 1999 ME 172, 740 A.2d 992, 1999 Me. LEXIS 181 (Me. 1999).

Opinion

WATHEN, C.J.

[¶ 1] The insurers, Great American Insurance Co. and Maine Employers’ Mutual Insurance Co. (“MEMIC”) appeal from a decision of the Workers’ Compensation Board, granting the employee’s petitions relating to work-injuries that occurred in 1985 and 1994. The insurers challenge the retroactive application of 39-A M.R.S.A. § 201(6) (Supp.1998), the apportionment of liability between insurers pursuant to 39-A M.R.S.A. § 354 (Supp.1998), and the inclusion of fringe benefits in the employee’s average weekly wage. We vacate that decision.

[¶ 2] The employee, Peter Hincks, suffered two injuries while employed by Robert Mitchell Co., d/b/a Douglas Brothers. The first injury occurred on November 20, 1985, while Douglas Brothers was insured by Great American. The second injury occurred on May 9, 1994, while Douglas Brothers was insured by MEMIC. The employee’s average weekly wage at the time of his 1994 injury was $717.37, based on an hourly rate of $23.06. A portion of that hourly rate consisted of $5.60 in employer-contributions to union-established benefit funds, which included: a $3.00 contribution to a health and welfare fund; a $1.60 contribution to a pension fund; and a $1.00 contribution to a local annuity fund.

[¶ 3] Hincks filed several petitions with the Board in 1994 seeking compensation for the two injuries. The Board granted the petitions in 1997 awarding ongoing seventy-two percent partial incapacity benefits. Although the Board found a causal relationship between the employee’s incapacity and both dates of injury, the Board ordered the most recent insurer, MEMIC, to pay all incapacity benefits pursuant to 39-A M.R.S.A. § 354. The Board also concluded, however, that “payments for medical service related to his back injury are to be divided equally between the two carriers; payments for treatments related to Mr. Hincks’ depression/anxiety are solely the responsibility of the May 9, 1994 date of injury.” Finally, relying on Ashby v. Rust Eng’g Co., 559 A.2d 774, 775 (Me.1989), the Board concluded that the employer-contributions to employee benefit funds were not fringe benefits, but more akin to bargained-for, dollar-for-dollar contributions on behalf of an employee, and, therefore, should be treated as part of the employee’s average weekly wage.

[¶4] All parties filed motions for further findings of fact and conclusions of law following the Board’s decision in 1997. While the motions were pending, the Legislature enacted P.L.1998, ch. 647 (effective June 30, 1998), codified at 39-A M.R.S.A. § 201(6). 1 In its subsequent decision in response to the motions for findings of fact, the Board concluded that subsection *994 201(6) applied to the pending proceeding, and that Hincks is therefore entitled to inflation adjustment for that portion of his incapacity attributable to his 1985 injury. 2 We granted both insurers’ petitions for appellate review pursuant to 39-A M.R.S.A. § 322 (Supp.1998).

[¶ 5] We agree with the insurers that the Board’s decision to apply subsection 201(6) to a proceeding pending on the effective date of the statute was error pursuant to our recent decision in Loud v. Kezar Falls Woolen Co., 1999 ME 118, ¶ 11, 735 A.2d 965, 969. Because the Legislature chose not to make subsection 201(6) applicable to matters pending at the time of the amendment’s enactment, the liabilities of the parties are governed by our decision in Ray v. Carland Constr., Inc., 1997 ME 206, ¶ 4, 703 A.2d 648, 650. Pursuant to Ray, when more than one injury contributes to an employee’s incapacity and the most recent injury occurred after the effective date of title 39-A, the employee’s entitlement to benefits is governed exclusively by title 39-A.' Id. Accordingly, because title 39-A does not provide an inflation adjustment for partial benefits, Hincks is not entitled to an inflation adjustment for any portion of his incapacity.

[¶ 6] Great American contends further that, pursuant to section 354 and Rosetti v. Land Reclamation, 1997 ME 197, ¶ 5, 704 A.2d 312, 313, the Board had no authority to apportion medical benefits on a 50%/50% basis. We agree. Subsection 354(2) unmistakably provides that “the insurer providing coverage at the time of the last injury shall initially be responsible to the employee for all benefits payable under this Act.” 39-A M.R.S.A. § 354(3). After liability is assessed against the most recent insurer, that insurer is entitled to proceed against the previous insurers pursuant to section 354 for an apportionment. 39-A M.R.S.A. § 354(3); Rosetti 1997 ME 197, ¶ 5, 704 A.2d at 313. As we stated in Rosettt, subsection 354(3) provides that apportionment before the Bureau of Insurance is the “exclusive means” of resolving apportionment issues between insurers. 3 We conclude that the Board lacked authority to determine an apportionment of medical benefits between the insurers.

[¶ 7] MEMIC also contends that the Board erred in placing sole responsibility for the psychological condition on the 1994 injury. As we have stated, “[w]e give deference to the factual findings of the [Board], particularly when those findings require an evaluation of medical evidence.” See Mathieu v. Bath Iron Works, 667 A.2d 862, 864 (Me.1995). Accordingly, we decline to disturb this factual finding on appeal.

[¶ 8] Finally, MEMIC contends that the Board erred in concluding that the employer-payments to union-established funds were not fringe benefits. Paragraph 102(4)(H) provides:

H. “Average weekly wages, earnings or salary” does not include any fringe or other benefits paid by the employer that continue during the disability. Any fringe or other benefit paid by the employer that does not continue during the disability must be included for purposes of determining an employee’s average weekly wage to the extent that the inclusion of the fringe or other benefit will not result in a weekly benefit amount *995 that is greater than ⅜ of the state average weekly wage at the time of the injury.

39-A M.R.S.A. § 102(4)(H) (Supp.1998). MEMIC argues that, because the employer-contributions are a fringe benefit and because the inclusion of those contributions increases the employee’s weekly benefits above two-thirds of the state average weekly wage at the time of his injury, the employer is entitled to a limited reduction in benefit payments pursuant to paragraph 102(4)(H). See, e.g., O’Neal v. City of Augusta, 1998 ME 48A, ¶¶4-6, 706 A.2d 1042, 1043-44.

[¶ 9] There is no dispute that the employer-contributions are identical to those in Ashby, 559 A.2d at 775. In Ashby, we held that employer payments to union-negotiated funds must be included in the average weekly wage when the benefits are paid out of bargained-for, dollar-for-dollar deductions from the employee’s pay. Id. As MEMIC suggests, however, shortly after our decision in Ashby,

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

Related

Appeal of Gagnon
965 A.2d 1154 (Supreme Court of New Hampshire, 2009)
Shaw v. U.S. Airways, Inc.
652 S.E.2d 22 (Court of Appeals of North Carolina, 2007)
Arsenault v. J.A. Thurston Co.
2004 ME 83 (Supreme Judicial Court of Maine, 2004)
Ricci v. Mercy Hospital
2002 ME 173 (Supreme Judicial Court of Maine, 2002)
Coulombe v. Anthem Blue Cross/Blue Shield of Maine, Inc.
2002 ME 163 (Supreme Judicial Court of Maine, 2002)
McAdam v. United Parcel Service & Helmsman Management Services, Inc.
2001 ME 4 (Supreme Judicial Court of Maine, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
1999 ME 172, 740 A.2d 992, 1999 Me. LEXIS 181, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hincks-v-robert-mitchell-co-me-1999.