Lorraine Somers v. S.D. Warren Company

2020 ME 137, 242 A.3d 1091
CourtSupreme Judicial Court of Maine
DecidedDecember 15, 2020
StatusPublished
Cited by2 cases

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Bluebook
Lorraine Somers v. S.D. Warren Company, 2020 ME 137, 242 A.3d 1091 (Me. 2020).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2020 ME 137 Docket: WCB-20-60 Argued: September 16, 2020 Decided: December 15, 2020

Panel: MEAD, GORMAN, JABAR, HUMPHREY, and HORTON, JJ.

LORRAINE SOMERS

v.

S.D. WARREN COMPANY et al.

MEAD, J.

[¶1] In December 2014, the Workers’ Compensation Board (Elwin, HO)1

entered a decree permitting S.D. Warren Company and its insurer, Constitution

State Services (collectively S.D. Warren), to discontinue paying Lorraine

Somers partial incapacity benefits because those payments had reached a

520-week statutory limit. See 39-A M.R.S. § 213(1)(A), (4) (2014).2

[¶2] Somers petitioned to have her benefits reinstated, asserting that

S.D. Warren had failed to comply with Me. W.C.B. Rule, ch. 2, § 5(1) (2017) (“the

1 Before October 15, 2015, Administrative Law Judges deciding workers’ compensation cases were known as Hearing Officers. See P.L. 2015, ch. 297 (effective Oct. 15, 2015).

2 The statute has since been amended, but not in a way that affects this appeal. P.L. 2015, ch. 297, § 8 (effective Oct. 15, 2015); P.L. 2017, ch. 288, § A-50 (effective July 15, 2017) (codified at 39-A M.R.S. § 213(1)(A), (4) (2020)). 2

former Rule”)3 by not providing her, before it ceased making payments, with

notice that she could be eligible for an extension of weekly benefits. Although

an Administrative Law Judge (Elwin, ALJ) denied the petition for reinstatement

of benefits, the Workers’ Compensation Board Appellate Division vacated that

decision after Somers appealed.

[¶3] The Appellate Division concluded that the notice requirement of the

former Rule was applicable to Somers’s petition and that, because S.D. Warren

admitted that it had not sent the notice, it was required to pay Somers all

benefits owed to her from the date they were discontinued pursuant to the

2014 decree. The Appellate Division further concluded that the decree did not

impose a res judicata bar on Somers’s petition. On S.D. Warren’s appeal from

the decision of the Appellate Division, we affirm.

I. BACKGROUND

[¶4] In December 2000, Somers suffered a right knee injury while

working for S.D. Warren. She returned to work in a work-hardening capacity

3The Rule was amended on September 1, 2018, by adding subsection 1-A, which shifts the burden to provide notice from the employer to the Board in cases where an order of compensation has been entered. See Me. W.C.B. Rule, ch. 2, § 5(1)-(1-A) (2020). Accordingly, the principal legal issue in this case will not recur in petitions filed after the amendment took effect. The version of the rule applicable to Somers’s petition, Me. W.C.B. Rule, ch. 2, § 5(1) (2017), is referred to in this opinion as “the former Rule.” The former Rule was virtually unchanged during the twenty years from its adoption in 1998 to its 2018 amendment. 3

in October 2001 and resumed her regular job in December 2001. After her

symptoms worsened, she went out of work in March 2005 and was terminated

two years later.

[¶5] In a July 2008 decree, the Workers’ Compensation Board found that

the injury Somers sustained in 2000 was compensable and that she was entitled

to ongoing 100 percent partial incapacity benefits. In March 2013, S.D. Warren

filed a petition for review seeking to discontinue benefits on the ground that

Somers’s entitlement to them had ended pursuant to a 520-week statutory cap.

See 39-A M.R.S. § 213(1)(A), (4). The Board found in its December 2014 decree

that 520 weeks of benefits had been paid and that Somers’s permanent

impairment level fell below the 11.8 percent threshold established by

Me. W.C.B. Rule, ch. 2, § 1(1) (2014), and therefore S.D. Warren was entitled to

discontinue payment of benefits, see 39-A M.R.S. §§ 205(9)(B)(2), 213(1)(A),

(4) (2014).

[¶6] In May 2015, Somers filed a petition for reinstatement of benefits,

see 39-A M.R.S. § 205(9)(C) (2020), arguing that S.D. Warren had failed to send

the notice required by the former Rule and that she was entitled to continuing 4

benefits until the company did so.4 The version of the Rule in effect at the time

provided,

Prior to cessation of benefits pursuant to 39-A M.R.S.A. § 213(1), the employer must notify the employee that the employee’s lost time benefits are due to expire. The notice must be sent at least 21 days in advance of the expiration date, and must include the date the lost time benefits are due to expire and the following paragraph:

If you are experiencing extreme financial hardship due to inability to return to gainful employment, you may be eligible for an extension of your weekly benefits. To request such an extension, you must file a Petition for Extension of Benefits within 30 calendar days of the date that benefits expire, or, in cases where the expiration date is contested, within 30 calendar days of a final decree as to the expiration date.

Failure to send the required notice will automatically extend the employee’s entitlement to lost time benefits for the period that the notice was not sent.

Notice shall be considered “sent” if it is mailed to the last address to which a compensation check was sent.

Me. W.C.B. Rule, ch. 2, § 5(1) (2017).

[¶7] In a 2017 decision denying Somers’s petition, the Board (Elwin, ALJ)

construed the former Rule as applying solely to cases in which an employer

seeks a “prospective” discontinuation of benefits, rather than in cases where, as

4The parties stipulated that S.D. Warren had not issued a notice of Somers’s right to request an extension of benefits for extreme financial hardship pursuant to the former Rule. 5

here, a Board decree allows “immediate” discontinuation of benefits. Somers

moved for further findings. See 39-A M.R.S. § 318 (2020). When her motion

was denied, Somers appealed to the Appellate Division. See 39-A M.R.S. § 321-B

(2020).

[¶8] In January 2020, the Appellate Division vacated the decision,

construing the plain language of the former Rule to require the prescribed

notice before S.D. Warren could terminate Somers’s benefits. The Appellate

Division further concluded that the former Rule did not exceed the Board’s

rulemaking authority and that Somers’s notice argument was not barred by

res judicata. We granted S.D. Warren’s petition for appellate review. See

39-A M.R.S. § 322(3) (2020); M.R. App. P. 23.

II. DISCUSSION

A. Res Judicata

[¶9] S.D. Warren contends that because Somers did not claim a lack of

notice when contesting the company’s 2013 petition seeking to terminate her

benefits, the res judicata doctrine barred her from doing so when she sought to

reinstate her benefits following the Board’s 2014 decree. The Appellate

Division disagreed, concluding that “[b]ecause S.D. Warren did not cease paying

benefits until after the 2014 decree, the factual issue of whether notice was 6

provided to Ms. Somers was not before the board during that litigation.” We

review de novo the Appellate Division’s determination that res judicata did not

bar Somers’s petition to reinstate her benefits. See Portland Water Dist. v. Town

of Standish, 2008 ME 23, ¶ 7, 940 A.2d 1097.

[¶10] “[V]alid and final decisions of the Workers’ Compensation Board

are subject to the general rules of res judicata . . . .” Bailey v. City of Lewiston,

2017 ME 160, ¶ 10, 168 A.3d 762 (quotation marks omitted). The claim

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2020 ME 137, 242 A.3d 1091, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lorraine-somers-v-sd-warren-company-me-2020.