Indiana Compensation Rating Bureau v. Technology Insurance Company

CourtIndiana Court of Appeals
DecidedOctober 24, 2024
Docket24A-PL-857
StatusPublished

This text of Indiana Compensation Rating Bureau v. Technology Insurance Company (Indiana Compensation Rating Bureau v. Technology Insurance Company) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Indiana Compensation Rating Bureau v. Technology Insurance Company, (Ind. Ct. App. 2024).

Opinion

IN THE

Court of Appeals of Indiana Indiana Compensation Rating Bureau, Appellant-Defendant FILED Oct 24 2024, 9:21 am And CLERK Indiana Supreme Court Court of Appeals and Tax Court Indiana Department of Insurance Defendant

v.

Technology Insurance Company, Appellee-Plaintiff

October 24, 2024 Court of Appeals Case No. 24A-PL-857 Appeal from the Marion County Superior Court, Civil Division The Honorable James Joven, Judge Trial Court Cause No. 49D13-2207-PL-22174

Court of Appeals of Indiana | Opinion 24A-PL-857 | October 24, 2024 Page 1 of 15 Opinion by Judge Bailey Judges Bradford and Foley concur.

Bailey, Judge.

Case Summary [1] Technology Insurance Company (“TIC”) sought reimbursement from the

Indiana Compensation Rating Bureau, as Administrator of the Indiana

Assigned Risk Reinsurance Plan, (“ICRB”) for TIC’s payment of a worker’s

compensation claim and attorney’s fees incurred in litigation of that claim.

ICRB denied the request for reimbursement, and TIC appealed to the Indiana

Department of Insurance (“IDOI”). IDOI issued a ruling that ICRB had

breached its contract. One day after the time for objections expired, TIC filed a

motion for prejudgment interest and attorney’s fees incurred in appealing the

denial of reimbursement. ICRB filed a request for judicial review in the Marion

Superior Court and IDOI advised the parties that jurisdiction was in that court.

After the dismissal of ICRB’s petition and months of correspondence from TIC,

IDOI did not set a hearing. TIC filed a petition for judicial review and obtained

an order from the Marion Superior Court, Civil Division, purportedly

Court of Appeals of Indiana | Opinion 24A-PL-857 | October 24, 2024 Page 2 of 15 remanding 1 to IDOI and ordering that it award TIC a specific amount of

attorney’s fees and prejudgment interest. ICRB appeals, contending that TIC

cannot recover the additional attorney’s fees and interest it seeks because, at the

very least, it did not first request those funds from ICRB. 2 Because we agree

that TIC has failed to exhaust its administrative remedies by not doing so, we

reverse.

Issue [2] ICRB articulates several issues for review. We address the dispositive issue:

whether the trial court erred in ordering that IDOI conduct further proceedings

and award prejudgment interest and appellate attorney’s fees to TIC absent TIC

first obtaining a decision on the prejudgment interest and appellate attorney’s

fees from ICRB.

Facts and Procedural History [3] ICRB is a statutorily created workers’ compensation insurance rating agency, 3

privately funded by the insurance industry, and operating under a license issued

by IDOI. Among other things, ICRB serves as the plan administrator of the

1 Although the trial court ordered the IDOI to conduct proceedings on remand, the trial court stated that it “shall retain jurisdiction over any petition for judicial review related to any further orders issued by the IDOI with respect to the dispute between TIC and the ICRB.” Appealed Order at 10. 2 IDOI is not an active party in this appeal. 3 See Ind. Code § 27-7-2-3.

Court of Appeals of Indiana | Opinion 24A-PL-857 | October 24, 2024 Page 3 of 15 Indiana Assigned Risk Reinsurance Pool (“the Pool”), which provides worker’s

compensation insurance for employers who are unable to secure insurance in

the voluntary market. ICRB acts as a reinsurer for worker’s compensation

losses properly paid, and it allocates expenses among its members. 4

[4] In November of 2013, member TIC executed an Indiana Assigned Risk

Reinsurance Pool Servicing Carrier Agreement (“the Agreement”) with ICRB

for a three-year term. 5 Pursuant to the Agreement, a member must accept all

risks assigned by the Plan Administrator and issue worker’s compensation

insurance policies to the risks. In turn, a member is to be reimbursed for

liabilities for losses under its policies and certain related expenses, absent a

showing of conduct in the handling of a claim that is willfully or intentionally

wrong, fraudulent, or criminal. The Agreement provides that “in the event

legal action is initiated by either Party for breach of this Agreement, the

prevailing Party shall be entitled to recover in addition to all other damages,

attorney’s fees, expenses and costs.” (App. Vol. II, pg. 41.)

[5] In July of 2017, TIC submitted a reimbursement request to ICRB in the amount

of $2,855,329. This consisted of $2,050,000 TIC had paid in connection with

4 Indiana Code Section 27-7-2-3 provides: “After July 1, 1935, every insurance company authorized to effect worker’s compensation insurance in this state shall be a member of the worker’s compensation rating bureau of Indiana. The bureau shall be composed of all insurance companies lawfully engaged on July 1, 1935, wholly or in part in making worker’s compensation insurance in Indiana or who shall after July 1, 1935, be issued a certificate of authority to make worker’s compensation insurance in this state.” 5 ICRB binds insurance coverage for employers and contracts with one of its members to administer a policy issued through the Indiana Assigned Risk Reinsurance Pool. The member is then considered to be a Servicing Carrier.

Court of Appeals of Indiana | Opinion 24A-PL-857 | October 24, 2024 Page 4 of 15 several lawsuits, collectively referred to by the parties as the Omega

McWorthey litigation, 6 and related attorney’s fees and costs of $805,329. On

June 14, 2018, ICRB notified TIC that the ICRB Board of Directors had denied

the reimbursement request.

[6] TIC decided to pursue its right of appeal, set forth in the Agreement as follows:

A Servicing Carrier shall have the right to appeal a decision by the Plan Administrator to the Governing Board of the Plan Administrator (the "Governing Board"), provided however, such appeal must be filed with the Governing Board not later than thirty (30) days after the date of the decision by the Plan Administrator. The Governing Board shall either (i) render a decision on the appeal, or (ii) submit the appeal to a committee appointed by the Governing Board, which will render a decision on the appeal. In the event a Servicing Carrier fails to timely appeal the decision within thirty (30) days after the date of the decision, the Servicing Carrier shall be deemed to have waived such appellate right and the decision of the Plan Administrator shall become final and non-appealable without any further action.

A Servicing Carrier shall have the right to appeal a decision by the Governing Board to the Department, provided however, such appeal must be filed with the Department not later than thirty (30) days after the date of the decision by the Governing Board. The Department shall render a decision on the appeal. In the event a Servicing Carrier fails to timely appeal the decision of the

6 In 2013, the ICRB received an application for insurance from Omega Demolition Corporation. ICRB agreed to provide coverage and assigned its obligation to TIC to issue an Indiana Assigned Risk Workers Compensation and Employers Liability Insurance Policy to Omega effective July 24, 2013. (ALJ Order, para. 28.) A claim on the policy was filed by Omega relating to an injury to its employee James McWorthey that gave rise to multiple lawsuits.

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