Patrick Ryan v. State of Missouri, Second Injury Fund

CourtMissouri Court of Appeals
DecidedNovember 26, 2024
DocketED112149
StatusPublished

This text of Patrick Ryan v. State of Missouri, Second Injury Fund (Patrick Ryan v. State of Missouri, Second Injury Fund) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patrick Ryan v. State of Missouri, Second Injury Fund, (Mo. Ct. App. 2024).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION FOUR

PATRICK RYAN, ) No. ED112149 ) Appellant, ) Appeal from the Labor and ) Industrial Relations Commission vs. ) ) STATE OF MISSOURI, SECOND INJURY ) FUND, ) ) Respondent. ) Filed: November 26, 2024

Introduction

Patrick Ryan (“Ryan”) appeals the Labor and Industrial Relations Commission’s

(“Commission”) decision denying his claim against the Second Injury Fund (“Fund”) for

permanent total disability (“PTD”) benefits. This appeal turns on the application of § 287.220.31

(“Subsection 3”) of the Missouri Workers’ Compensation Act (“Act”), which applies to all PTD

claims against the Fund. Pertinent to this appeal is the first condition of Subsection 3, that provides

a claimant is entitled to PTD benefits if the claimant has at least one qualifying pre-existing

disability equaling a minimum of 50 weeks of permanent partial disability (“PPD”), and which is

“[a] direct result of a compensable injury as defined in section 287.020.” §§ 287.220.3(2)(a)a–

287.220.3(2)(a)a(ii).

1 All references are to Mo. Rev. Stat. Cum. Supp. (2015), unless otherwise stated. The basic questions before this Court are: 1) whether a portion of a prior award of enhanced

PPD can be considered in a subsequent PTD claim against the Fund in determining if the claimant

has met the 50-week statutory threshold; and 2) whether a portion of a prior award of enhanced

PPD can be considered a direct result of a compensable injury. This Court concludes the answer

to both questions is: Yes. Accordingly, the Commission’s award denying Ryan Fund benefits is

reversed.

Background

A. The Missouri Workers’ Compensation Act and the Second Injury Fund

Before discussing the facts and merits of Ryan’s appeal, we review the purpose and

function of the Act and the Fund. In 1925, the Act established the rights and responsibilities of

employees and employers in the event an employee suffers an on-the-job injury that results in

measurable disability to an identifiable part of the body or to the body as a whole (“BAW”). See

Gunnett v. Girardier Bldg. & Realty Co., 70 S.W.3d 632, 635 n.2 (Mo. App. E.D. 2002);

§ 287.190. The legislature amended § 287.220 in 1943 to establish the Fund to encourage the

employment of the partially handicapped, that is, an employee with one or more pre-existing

disabilities. See Fed. Mut. Ins. Co. v. Carpenter, 371 S.W.2d 955, 957 (Mo. 1963); see also

Lawrence v. Treasurer of State—Custodian of Second Injury Fund, 470 S.W.3d 6, 9 n.1 (Mo. App.

W.D. 2015). The Fund’s framework ensures “[t]he employer is liable only for the disability

resulting from the work-related compensable injury, and the [Fund] is liable only for the

percentage of disability which exceeds the sum of the two disabilities by reason of their

combination.” Searcy v. McDonnell Douglas Aircraft Co., 894 S.W.2d 173, 178 (Mo. App. E.D.

1995) (overruled on other grounds). The Fund becomes liable when the pre-existing disability is

combined with the compensable disability from the primary injury and results “in a greater degree

2 of disability than the sum of the two disabilities, that is, a synergistic enhancement in which the

combined totality is greater than the sum of the independent parts.” Id. As a result, “[t]he employer

is liable only for the disability resulting from the work-related compensable injury, and the Second

Injury Fund is liable only for the percentage of disability which exceeds the sum of the two

disabilities by reason of their combination.” Id.

For purposes of Fund liability, a claimant’s injuries are characterized as PPD or PTD. PPD

“is a disability that is permanent in nature and partial in degree.” Jim Plunkett, Inc. v. Ard, 499

S.W.3d 333, 339 (Mo. App. W.D. 2016) (internal quotations and citation omitted). Conversely,

“[PTD] arises when the employee’s injury is such that the employee has become permanently

unemployable on the open labor market and is entitled to benefits through the remainder of the

employee’s lifetime.” Nivens v. Interstate Brands Corp., 585 S.W.3d 825, 835 (Mo. App. W.D.

2019).

Until 2013, Missouri workers could make claims for PPD and PTD benefits from the Fund.

That changed when the legislature amended § 287.220 to “limit the number of workers eligible for

fund benefits because the Fund was insolvent.” Treasurer of State v. Parker, 622 S.W.3d 178, 181

(Mo. banc 2021). The legislature created two subsections: Subsection 2 is limited to compensable

work injuries occurring before January 1, 2014, and Subsection 3, the provision at issue here, is

limited to compensable work injuries occurring after January 1, 2014. Id.

The two subsections outline two different frameworks to determine Fund benefits.

Subsection 2 retained the pre-amendment framework for Fund benefits, requiring an employee to

demonstrate the pre-existing disability was a hindrance or obstacle to employment and, if the

disability was to the BAW, at least 50 weeks or if the disability was to a major extremity, at least

fifteen percent. § 287.220.2. Conversely, Subsection 3 eliminated all PPD claims against the Fund

3 and limited the Fund’s liability to PTD claims that could satisfy the new, more stringent

requirements of Subsection 3 at issue here. And Subsection 3 omitted both the “hindrance or

obstacle” requirement and any reference to a minimum percent of disability. Parker, 622 S.W.3d

at 181; compare § 287.220.2 with § 287.220.3.

B. Factual Background relevant to this appeal

Beginning in eighth grade, Ryan worked in various trades over five decades. After high

school, Ryan worked at Burlington Northern Railroad doing heavy labor. He then worked at

Quincy Soybean for twenty-five years loading, unloading, and repairing river barges. Next, Ryan

worked at Pillsbury General Mills for approximately four years doing machinery repairs and

general maintenance work. Last, Ryan worked for the Hannibal Board of Public Works

(“Employer”) for approximately ten years before the 2015 primary injury giving rise to this case.

Throughout his career, Ryan suffered several work-related injuries.

1. 2004 - right knee

In 2004, at Pillsbury General Mills, Ryan suffered an injury to his right knee. Ryan

underwent several surgeries and eventually had a knee replacement. The 2004 right knee injury

resulted in a workers’ compensation settlement for 75% of the right knee or 120 weeks of PPD.

2. 2007 - left shoulder and cervical spine

In 2007, while working for Employer, Ryan hurt his left shoulder and cervical spine when

he fell six to seven feet onto a concrete floor. Ryan eventually underwent surgery for each injury.

He brought claims against Employer for the primary injuries and against the Fund for the disability

that resulted from his pre-existing 2004 injury in combination with the primary injuries to his left

shoulder and cervical spine. Ryan settled with Employer for 25% PPD (58 weeks) of the left

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Patrick Ryan v. State of Missouri, Second Injury Fund, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patrick-ryan-v-state-of-missouri-second-injury-fund-moctapp-2024.