State Industrial Insurance System v. Woodall

799 P.2d 552, 106 Nev. 653, 1990 Nev. LEXIS 123
CourtNevada Supreme Court
DecidedOctober 25, 1990
DocketNo. 20979
StatusPublished
Cited by5 cases

This text of 799 P.2d 552 (State Industrial Insurance System v. Woodall) is published on Counsel Stack Legal Research, covering Nevada Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Industrial Insurance System v. Woodall, 799 P.2d 552, 106 Nev. 653, 1990 Nev. LEXIS 123 (Neb. 1990).

Opinion

[654]*654OPINION

Per Curiam:

Respondent, Rebecca Ann Woodall, sustained a compensable industrial injury on September 16, 1987, when she slipped and fell during her shift as a card dealer at the Pioneer Club in Laughlin, Nevada. Woodall’s compensation at the Pioneer Club included her monthly salary of $441.80, as well as any tip income she received from her customers.

Woodall filed a claim with the State Industrial Insurance System (“SIIS”) for temporary total disability benefits because of her injury. Subsequently, SIIS informed Woodall that she would receive benefits, but that these benefits would be based upon her monthly salary of $441.80 only. SIIS refused to include Woodall’s tip income as part of her monthly wages. This resulted in smaller disability benefits for Woodall and, therefore, she sought relief in an appeal to an administrative hearing officer.

The hearing officer rejected Woodall’s request for relief. The officer reasoned Woodall was barred from including her tip income as part of her average monthly wage because she had not [655]*655reported her tips to her employer, the Pioneer Club, pursuant to the tip reporting guidelines established in NRS 616.401.1

Woodall appealed again to a Nevada Department of Administration appeals officer who found: (1) Woodall was not aware of the reporting requirements of NRS 616.401 because she had not received assistance from SIIS or her employer on how to comply with the statute; (2) Woodall’s employer was already aware of her tip income and probably kept track of the tip income through an internal audit; and (3) Woodall had filed an income tax return for 1987 declaring $7,100.00 as tip income.

The appeals officer then concluded a liberal and practical construction of NRS 616.401 was appropriate. In applying such a construction to the statute and the above findings of fact, the appeals officer concluded “that any reasonable notice, such as notice to the IRS, is sufficient notice to comply with NRS 616.401.” Woodall was given the relief she requested. SIIS was ordered to include her tip income as part of her average monthly wage and, consequently, Woodall’s disability benefits from SIIS were increased.

[656]*656SUS then filed a petition for judicial review with the district court. On judicial review, the district court concluded that employees who had to report their tip income to an employer did not have to comply with the tip reporting requirements of NRS 616.401, but, instead, reported their tip income pursuant to NRS 616.027(2).2 The district court further reasoned it would be “fundamentally unfair” not to include Woodall’s tips, reported to the Internal Revenue Service in an annual tax return, as part of her gross income for workman’s compensation purposes. Based upon these conclusions, the district court affirmed the appeals officer’s decision that any reasonable notice, including notice to the Internal Revenue Service in an annual tax return, is sufficient notice to comply with the reporting requirements established in NRS 616.401. This appeal followed.

REPORTING TIPS PURSUANT TO NRS 616.027(2)

The issues presented involve the proper construction of two statutes, NRS 616.027(2) and NRS 616.401, and, therefore, independent appellate review is appropriate. Nevada Emp. Sec. Dep’t v. Capri Resorts, 104 Nev. 527, 763 P.2d 50 (1988).

The district court compared NRS 616.027(2) and NRS 616.401, and concluded these two statutes conflicted with each other where NRS 616.027(2) does not establish a particularized procedure for reporting tips while NRS 616.401 does. The district court felt this conflict required judicial interpretation of the statutes, and, after such an interpretation, reasoned NRS 616.401 was remedial legislation intended to cover a specific “class” of persons who had exclusive knowledge of their tip income.3 The district court further reasoned that NRS 616.027(2) was intended to cover another “class” of tip earners who did not have exclusive knowledge of their tips, but could be required by their employers to report tip income. Based upon this analysis, the district court concluded that any employee like Rebecca Woodall, whose employer was aware of the amount of tip income the employee received, reported their tip income for the purposes of compensation benefits pursuant to NRS 616.027(2) and were not [657]*657required to comply with the voluntary tip reporting procedure outlined in NRS 616.401 in order to get SIIS disability payments based upon that tip income. We reject this analysis.

NRS 616.027(2) defines an employee’s “average monthly wage” to include cash tips reported by an employee to his employer unless the tips total less than $20.00 per month. However, this statute does not establish a procedure for reporting tips to either the employer, or to SIIS. More importantly, NRS 616.027(2) does not require the employer to pay increased premium payments to SIIS based upon the reported tip income, while NRS 616.401 does. See NRS 616.401(2)(e).

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Cite This Page — Counsel Stack

Bluebook (online)
799 P.2d 552, 106 Nev. 653, 1990 Nev. LEXIS 123, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-industrial-insurance-system-v-woodall-nev-1990.