Jeremy Thornhill v. Walker-Hill Environmental and Zurich American Insurance Company of Illinois

CourtCourt of Appeals of Mississippi
DecidedOctober 19, 2021
Docket2020-CA-01181-COA
StatusPublished

This text of Jeremy Thornhill v. Walker-Hill Environmental and Zurich American Insurance Company of Illinois (Jeremy Thornhill v. Walker-Hill Environmental and Zurich American Insurance Company of Illinois) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeremy Thornhill v. Walker-Hill Environmental and Zurich American Insurance Company of Illinois, (Mich. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2020-CA-01181-COA

JEREMY THORNHILL APPELLANT

v.

WALKER-HILL ENVIRONMENTAL AND APPELLEES ZURICH AMERICAN INSURANCE COMPANY OF ILLINOIS

DATE OF JUDGMENT: 09/11/2020 TRIAL JUDGE: HON. ANTHONY ALAN MOZINGO COURT FROM WHICH APPEALED: MARION COUNTY CIRCUIT COURT ATTORNEYS FOR APPELLANT: RAYNETRA LASHELL GUSTAVIS ROGEN K. CHHABRA DARRYL MOSES GIBBS ATTORNEYS FOR APPELLEES: OLIVIA YEN TRUONG DORIS THERESA BOBADILLA NATHAN L. BURROW NATURE OF THE CASE: CIVIL - TORTS-OTHER THAN PERSONAL INJURY AND PROPERTY DAMAGE DISPOSITION: REVERSED AND REMANDED - 10/19/2021 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE WILSON, P.J., McCARTY AND SMITH, JJ.

WILSON, P.J., FOR THE COURT:

¶1. Jeremy Thornhill alleged that he injured his back while working for Walker-Hill

Environmental. He sought workers’ compensation benefits from Walker-Hill and its

insurance carrier, Zurich American Insurance Company of Illinois (collectively, “the

Employer/Carrier”), but the Employer/Carrier denied that Thornhill had sustained a

compensable injury. The parties eventually entered into a compromise settlement, which the

Mississippi Workers’ Compensation Commission approved. After the Commission approved the settlement, Thornhill sued the Employer/Carrier in circuit court, alleging that they had

denied his claim in bad faith. The Employer/Carrier filed a motion to dismiss, arguing that

Thornhill had not exhausted his administrative remedies—and that the circuit court lacked

jurisdiction—because the Commission never made a factual finding that he was entitled to

workers’ compensation benefits. The circuit court agreed and dismissed the case. On appeal,

Thornhill argues that the Commission’s approval of the compromise settlement exhausted

his administrative remedies and that his bad-faith lawsuit against the Employer/Carrier may

go forward in the circuit court. For the reasons discussed below, we agree and reverse and

remand the case for further proceedings consistent with this opinion.

FACTS AND PROCEDURAL HISTORY

¶2. Thornhill worked at Walker-Hill as a supervisor driller. He alleges that he injured his

back while attempting to move a heavy rig on July 5, 2017. He alleges that he reported his

injury to his supervisor the following day, but Walker-Hill denies this allegation. On July

7, Walker-Hill asked Thornhill to take a drug test. Thornhill went to the testing facility and

provided a sample, but the sample was reportedly “cold” (i.e., below the minimum acceptable

temperature for testing). Thornhill says that he tried to produce a second sample but was

unable to do so, and he left without providing a second sample. Walker-Hill says that

Thornhill did not return to work for several days and was fired for refusing to submit to a

drug screen. Thornhill began seeing a doctor for his back injury, and the doctor eventually

recommended that Thornhill undergo back surgery.

¶3. In October 2017, Thornhill filed a petition to controvert with the Commission. In

2 November 2017, the Employer/Carrier filed an answer in which they admitted both that

Thornhill’s injury arose out his employment and that they had received proper notice of the

injury. However, the Employer/Carrier denied that Thornhill was entitled to benefits, citing

his refusal to complete the drug test. In April 2018, the Employer/Carrier filed an amended

answer in which they denied that Thornhill had suffered any work-related injury and denied

that they had received proper notice of the injury.1

¶4. Following a hearing, an administrative judge ordered Thornhill to undergo an

independent medical examination (IME) by Dr. Robert McGuire to “determine [Thornhill’s]

current condition and need for medical treatment.” In his subsequent report, Dr. McGuire

noted that Thornhill had been injured at work in 2015 but was able to return to work and

function normally following conservative treatment. Dr. McGuire concluded that the surgery

recommended by Thornhill’s treating physician was “absolutely appropriate.” Dr. McGuire

concluded that Thornhill needed back surgery because of his injury in July 2017, which had

“substantially aggravated [his] preexisting condition.” Finally, Dr. McGuire concluded that

Thornhill had not reached maximum medical improvement (MMI) and would not reach MMI

until approximately six months post-surgery.

1 The Employer/Carrier state that their attorney in the workers’ compensation case initially believed that the injury occurred on the job and that Walker-Hill received notice because the attorney thought that Thornhill’s July 7 drug test was a post-accident drug test. But the Employer/Carrier now assert that “the drug test was not a post-accident drug screen” and that Thornhill “never reported a work injury . . . prior to filing his [p]etition to [c]ontrovert.” The Employer/Carrier say that they filed an amended answer in the workers’ compensation case after their attorney was advised of his mistake. However, the Employer/Carrier’s amended answer continued to assert that Thornhill was not “entitled to benefits due to his refusal to undergo drug testing.”

3 ¶5. After receiving Dr. McGuire’s IME report, the parties reached a settlement. In July

2019, Thornhill filed an application, which the Employer/Carried joined, for the Commission

to approve their compromise settlement. The application stated that Thornhill contended that

he was entitled to benefits, while the Employer/Carrier denied that Thornhill had sustained

a compensable injury. However, the Employer/Carrier had agreed to pay Thornhill $145,000

to settle the claim. The application stated that it was made pursuant to Mississippi Code

Annotated section 71-3-29 (Rev. 2011) because the compensability of Thornhill’s injury was

“in issue and [it was] impossible to determine the exact extent of the disability suffered by

[Thornhill], if any.” The Commission found that the settlement was in Thornhill’s best

interest, approved the settlement, and dismissed the case with prejudice.

¶6. Pursuant to the settlement, Thornhill signed a general release that released the

Employer/Carrier from all claims arising out of or connected with his alleged on-the-job

injury. However, the general release included the following carve-out:

[Thornhill] reserves and does not release, however, the right to bring a claim for bad faith against any party and the parties agree administrative remedies in [Thornhill’s] workers’ compensation claim have been fully and finally exhausted.

The Employer/Carrier acknowledge that they drafted the release and included the above-

quoted language at the request of Thornhill’s attorney.

¶7. In January 2020, Thornhill sued the Employer/Carrier in circuit court, alleging bad-

faith denial of his workers’ compensation claim. The Employer/Carrier answered and later

filed a motion to dismiss, arguing that Thornhill had not exhausted his administrative

remedies. Specifically, the Employer/Carrier argued that the compromise settlement did not

4 exhaust Thornhill’s administrative remedies because the Commission never made a finding

that Thornhill had a compensable claim or was entitled to benefits. They further argued that

the circuit court lacked “jurisdiction” because the Commission had never made such a

finding. The circuit court agreed and granted the motion to dismiss. The court reasoned that

prior to filing suit for a bad-faith denial of workers’ compensation benefits, a plaintiff must

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Jeremy Thornhill v. Walker-Hill Environmental and Zurich American Insurance Company of Illinois, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeremy-thornhill-v-walker-hill-environmental-and-zurich-american-insurance-missctapp-2021.