Lavaca School District and Arkansas School Boards Association v. Pat Hatfield

2019 Ark. App. 360
CourtCourt of Appeals of Arkansas
DecidedSeptember 4, 2019
StatusPublished
Cited by1 cases

This text of 2019 Ark. App. 360 (Lavaca School District and Arkansas School Boards Association v. Pat Hatfield) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lavaca School District and Arkansas School Boards Association v. Pat Hatfield, 2019 Ark. App. 360 (Ark. Ct. App. 2019).

Opinion

Cite as 2019 Ark. App. 360 Digitally signed by Elizabeth ARKANSAS COURT OF APPEALS Perry Date: 2022.07.22 10:12:56 DIVISION I -05'00' No. CV-19-69 Adobe Acrobat version: 2022.001.20169 Opinion Delivered September 4, 2019 LAVACA SCHOOL DISTRICT AND ARKANSAS SCHOOL BOARDS APPEAL FROM THE ARKANSAS ASSOCIATION WORKERS’ COMPENSATION COMMISSION APPELLANTS [NO. G408038]

V.

PAT HATFIELD AFFIRMED

APPELLEE

LARRY D. VAUGHT, Judge

Appellants Lavaca School District and Arkansas School Boards Association

(collectively “the district”) appeal the Arkansas Workers’ Compensation Commission’s

(Commission) decision reversing the decision of the administrative law judge (ALJ) who

denied appellee Pat Hatfield’s request for additional medical benefits. While the ALJ

concluded that Hatfield’s claim was barred by the statute of limitations, the Commission

disagreed and found that she had received reasonable and necessary medical treatments that

tolled the statute of limitations. This factual finding is supported by substantial evidence, so

we affirm the Commission’s decision.

Hatfield was employed by the district when she first sustained an undisputedly

compensable injury to her right knee as a result of falling in the bathroom on April 11, 2014. Hatfield filed for workers’-compensation benefits on October 3, 2014, and the district

subsequently paid for medical treatment, including surgery.

Hatfield had what she called a “flare up” with her right knee in July 2015 and received

medical treatment until December 29, 2015 when her treating physician, Dr. Trent Johnson,

released her to work with no restrictions. On March 14, 2016, Lavaca School District’s

attorney emailed Hatfield’s attorney and Dr. Johnson, advising them that Hatfield must

request and receive advance authorization for any additional medical treatment related to her

knee injury. Hatfield was then treated by Dr. Johnson, without requesting or obtaining

advanced authorization, on May 6 and June 21, 2016. At both of these appointments, Hatfield

complained of pain in her right leg, shooting down from her back and hip. She was prescribed

physical therapy for her back and given an injection in her hip. On April 27, 2017, Hatfield

was again seen by Dr. Johnson, without advance authorization, for problems specifically

related to her right knee. The district did not pay for any of the three treatments for which

Hatfield failed to obtain prior approval.

On March 1, 2018, Hatfield filed a claim for additional medical benefits for her right

knee stemming from her compensable injury. Although the district initially claimed to have

provided all reasonable and necessary treatment up to and through June 21, 2016, it later

revised its position and asserted that the last benefits that had been paid on Hatfield’s claim

were in December 2015, which would make her claim for additional benefits time-barred

under the applicable statute of limitations.

The ALJ agreed with the district, concluding that Hatfield’s claim for additional

benefits was time-barred. Hatfield appealed to the Commission, which found that Hatfield

2 had received periodic medical treatment that was reasonable and necessary to treat her

compensable injury and that the statute of limitations was therefore tolled. The Commission

reversed the ALJ’s decision, and this appeal followed.

To the extent that the issue before us includes pure questions of law, we review such

issues de novo. Stewart v. Ark. Glass Container, 2010 Ark. 198, at 6–7, 366 S.W.3d 358, 361–62.

It is for this court to decide what a statute means, and we are not bound by the Commission’s

interpretation and application of the statute. Id. Regarding findings of fact, however, we view

the evidence and all reasonable inferences deducible therefrom in the light most favorable to

the Commission’s findings, and we affirm if the decision is supported by substantial evidence.

Graves v. Hopper, 2018 Ark. App. 193, at 11, 547 S.W.3d 448, 454. Substantial evidence exists

if reasonable minds could reach the Commission’s conclusion. Id. We will not reverse the

Commission’s decision unless fair-minded persons with the same facts before them could not

have reached the Commission’s conclusions. Id. The issue is not whether we might have

reached a different result or whether the evidence would have supported a contrary finding.

Id. Questions of weight and credibility are within the sole province of the Commission, which

is not required to believe the testimony of the claimant or of any other witness but may accept

and translate into findings of fact only those portions of the testimony it deems worthy of

belief. Id. Once the Commission has made its decision on issues of credibility, the appellate

court is bound by that decision. Id.

The only issue before us is whether Hatfield’s March 5, 2018 application for additional

medical benefits is barred by Arkansas Code Annotated section 11-9-702(b), which states in

pertinent part:

3 (b) Time for Filing Additional Compensation. (1) In cases in which any compensation, including disability or medical, has been paid on account of injury, a claim for additional compensation shall be barred unless filed with the commission within one (1) year from the date of the last payment of compensation or two (2) years from the date of the injury, whichever is greater.

....

(c) A claim for additional compensation must specifically state that it is a claim for additional compensation. Documents which do not specifically request additional benefits shall not be considered a claim for additional compensation.

Ark. Code Ann. § 11-9-702(b) (Repl. 2012). The Arkansas Supreme Court construes the term

“last payment of compensation” as including the date the employer or carrier last furnished

medical services. Plante v. Tyson Foods, Inc., 319 Ark. 126, 129–31, 890 S. W.2d 253–256 (1994).

The one-year limitations period runs from the date of the last furnishing of medical services,

not the payment therefor. Id.

The parties disagree on the legal significance of Hatfield’s failure to obtain prior

authorization for the treatments as requested by the district. While the district argues that it

did not furnish medical services to Hatfield because it only agreed to pay if she obtained prior

authorization, Hatfield contends that the district’s request that she obtain prior authorization

was of no legal effect because Dr. Johnson was an authorized provider to treat Hatfield’s

admittedly compensable injury, and the district had no authority to unilaterally impose

conditions and restrictions on those benefits. We affirm the Commission’s finding that failure

to comply with the district’s pre-authorization requirements does not bar Hatfield from

seeking additional benefits. The district has cited no authority for the idea that one party may

unilaterally impose such conditions on the benefits it provides for a compensable injury.

4 Moreover, our caselaw makes clear that it is the furnishing of medical treatment that tolls the

statute of limitations, not the payment for such treatment. See Plante, supra.

The parties also dispute whether Hatfield’s visits to Dr. Johnson in 2016 tolled the

statute of limitations. The district argues that the issue before us is a question of statutory

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