Sandra Amaya v. ICAO Brand X and Standard Fire

CourtColorado Court of Appeals
DecidedNovember 10, 2022
Docket22CA0467
StatusPublished

This text of Sandra Amaya v. ICAO Brand X and Standard Fire (Sandra Amaya v. ICAO Brand X and Standard Fire) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sandra Amaya v. ICAO Brand X and Standard Fire, (Colo. Ct. App. 2022).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY November 10, 2022

2022COA131

No. 22CA0467, Amaya v. Indus. Claim Appeals Off. — Workers’ Compensation — Death Benefits — Dependents — Apportionment — Compensation in Lump Sum — Proportionate Share

In this workers’ compensation appeal, a division of the court

of appeals concludes that the apportionment of death benefits

among a deceased worker’s dependents under section 8-42-121,

C.R.S. 2022, determines a dependent’s “proportionate share” of the

maximum lump sum allowed by statute under section 8-43-406(3),

C.R.S. 2022. The division thus affirms the Industrial Claim Appeals

Office order setting aside an order of the Director of the Division of

Workers’ Compensation and concluding that Sandra Amaya, a

dependent of decedent, Angel Batista de Jesus, was entitled to 25%

of the maximum lump-sum amount of Batista’s death benefits. COLORADO COURT OF APPEALS 2022COA131

Court of Appeals No. 22CA0467 Industrial Claim Appeals Office of the State of Colorado WC Nos. 5-117-273 & 5-149-129

Sandra Amaya, dependent of decedent, Angel Batista de Jesus,

Petitioner,

v.

Industrial Claim Appeals Office of the State of Colorado; Brand X Hydrovac Services, Inc.; and Standard Fire Insurance Company,

Respondents.

ORDER AFFIRMED

Division III Opinion by JUDGE FOX Tow and Yun, JJ., concur

Announced November 10, 2022

Kaplan Morrell, LLC, Britton J. Morrell, Greeley, Colorado, for Petitioner

Philip J. Weiser, Attorney General, Patrick L. Sayas, Senior Assistant Attorney General, Denver, Colorado, for Respondent Industrial Claim Appeals Office

Ray Lego and Associates, Jonathan S. Robbins, Greenwood Village, Colorado, for Respondents Brand X Hydrovac Services, Inc. and Standard Fire Insurance Company

Philip J. Weiser, Attorney General, Christopher K. Boeckx, Assistant Attorney General, Denver, Colorado, for Amicus Curiae Colorado Department of Labor and Employment, Division of Workers’ Compensation ¶1 In this workers’ compensation appeal, we must analyze the

interplay between two statutes: section 8-42-121, C.R.S. 2022,

which governs the apportionment of death benefits among a

deceased worker’s dependents, and section 8-43-406(3), C.R.S.

2022, which governs a lump-sum disbursement when there are

multiple dependents.

¶2 Section 8-42-121 reads,

Death benefits shall be paid to such one or more of the dependents of the decedent, for the benefit of all the dependents entitled to such compensation, as may be determined by the director, who may apportion the benefits among such dependents in such manner as the director may deem just and equitable.

¶3 A dependent may elect to receive part of the death benefits in a

lump sum. § 8-43-406(1). Section 8-43-406(3) then provides,

If a claimant who has been awarded compensation is one of multiple dependents of a deceased injured worker, the aggregate of all lump sums granted to the claimant must be a proportionate share, as determined by the director or administrative law judge, of an amount not to exceed [an annually adjusted maximum lump sum].

¶4 Specifically, we must determine whether the apportionment of

death benefits among the deceased worker’s dependents under

1 section 8-42-121 determines a dependent’s “proportionate share” of

the maximum lump sum allowed by section 8-43-406(3). We

conclude that it does.

¶5 An administrative law judge (ALJ) determined that Sandra

Amaya, a dependent of decedent, Angel Batista de Jesus, is entitled

to 25% of the benefits payable due to Batista’s death under section

8-42-121. Amaya then requested a lump-sum disbursement of the

death benefits under section 8-43-406(3) equating to 50% of the

maximum lump sum allowed by statute. The Director of the

Division of Workers’ Compensation (Director) granted her request.

However, the Industrial Claim Appeals Office (Panel) set aside the

Director’s order, concluding that Amaya is entitled to only 25% of

the maximum lump-sum amount.

¶6 Amaya appeals that final order. Because we conclude that an

apportionment of death benefits under section 8-42-121 controls a

dependent’s proportionate share of the maximum lump sum

allowed by section 8-43-406(3), we affirm the Panel’s final order.

I. Background

¶7 In August 2019, Batista suffered a fatal work injury during the

course and scope of his employment with Brand X Hydrovac

2 Services, Inc. (employer). Batista left two dependents: Amaya (his

wife) and their minor child, I.R. An ALJ apportioned the death

benefits between Amaya (25%) and I.R. (75%) under section

8-42-121. The employer and the carrier, Standard Fire Insurance

Company (collectively respondents), filed a General Fatal Admission

of Liability (GFAL), admitting to weekly death benefits of $255.64 to

Amaya and $766.92 to I.R.

¶8 Amaya then requested a lump-sum distribution of a portion of

her total death benefits in an amount equating to 50% of the

maximum lump sum available for the claim.

¶9 Respondents objected, arguing, as relevant here, that section

8-43-406(3) limits Amaya’s lump-sum disbursement because she is

one of two dependents and I.R.’s interests had not been addressed.

¶ 10 The Director granted Amaya’s request, awarded her 50% of the

maximum lump sum allowed by statute, and reduced her weekly

benefit amount by $86.27 to offset the benefits she would receive in

a lump sum (first disbursement order). The Director determined

that Amaya’s right to a lump sum vested on the filing of the GFAL,

so she could elect to receive any or all of the compensation up to

the statutory maximum.

3 ¶ 11 Respondents filed a petition to review the Director’s first

disbursement order, arguing, as relevant here, that the order was

contrary to applicable law. The Director dismissed the petition,

concluding that the order was not subject to review because it did

not award or deny a benefit or penalty.

¶ 12 Respondents then filed a petition for review by the Panel and a

brief in support of their petition. The Panel concluded that (1) the

Director’s order was reviewable to determine whether he had

exceeded his authority; (2) the ALJ had already determined Amaya’s

proportionate share of the lump sum (25%); and (3) the Director’s

findings were insufficient to determine whether he had correctly

applied section 8-43-406(3). So the Panel set aside the Director’s

order and remanded the case for the Director to make additional

findings and enter a new order.

¶ 13 On remand, the Director again awarded Amaya 50% of the

maximum lump sum allowed by statute (second disbursement

order), finding that

 sections 8-42-121 and 8-43-406(3) are in different

articles, have different methods of apportionment, and

are unrelated;

4  the authority to determine the proportionate share of a

lump sum is wholly distinct from and not contingent on

the authority to apportion benefits;

 the ALJ did not determine the proportionate share of the

lump sum;

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