Sturdivant v. N.C. Dep't of Pub. Safety

CourtSupreme Court of North Carolina
DecidedDecember 13, 2024
Docket130PA23
StatusPublished

This text of Sturdivant v. N.C. Dep't of Pub. Safety (Sturdivant v. N.C. Dep't of Pub. Safety) is published on Counsel Stack Legal Research, covering Supreme Court of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Sturdivant v. N.C. Dep't of Pub. Safety, (N.C. 2024).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

No. 130PA23

Filed 13 December 2024

MARTIN B. STURDIVANT, Employee

v. NORTH CAROLINA DEPARTMENT OF PUBLIC SAFETY, Employer, SELF- INSURED (CCMSI, Third-Party Administrator)

On discretionary review pursuant to N.C.G.S. § 7A-31 of a decision of a divided

panel of the Court of Appeals, 288 N.C. App. 470 (2023), affirming an opinion and

award entered on 28 February 2022 by the North Carolina Industrial Commission.

On 13 December 2023, the Supreme Court allowed plaintiff’s conditional petition for

discretionary review as to additional issues. Heard in the Supreme Court on 24

September 2024.

Poisson, Poisson & Bower, PLLC, by E. Stewart Poisson, for plaintiff- appellee/appellant.

Joshua H. Stein, Attorney General, by Lindsay Vance Smith, Deputy Solicitor General; Ryan Y. Park, Solicitor General; J. D. Prather, Special Deputy Attorney General; Heather A. Haney, Special Deputy Attorney General; and Marc D. Brunton, General Counsel Fellow, for defendant-appellant/appellee.

Lennon Camak & Bertics, PLLC, by Michael W. Bertics; and The Harper Law Firm, PLLC, by Richard B. Harper and Joshua O. Harper, for North Carolina Advocates for Justice, amicus curiae.

Brewer Defense Group, by Joy H. Brewer and Ginny P. Lanier; and Nelson Mullins Riley & Scarborough, LLP, by Andrew Heath, for North Carolina Association of Self-Insurers, North Carolina Forestry Association, North Carolina Retail Merchants Association, North Carolina Home Builders Association, American Property Casualty Insurance Association, and North Carolina Chamber Legal Institute, amici curiae. STURDIVANT V. N.C. DEP’T OF PUB. SAFETY

Opinion of the Court

DIETZ, Justice.

In 2011, the General Assembly amended our workers’ compensation laws with

the stated aim of putting people back to work. The amendment ended an employee’s

temporary total disability payments after 500 weeks unless the employee had

sustained a “total loss of wage-earning capacity.” Protecting and Putting North

Carolina Back to Work Act, S.L. 2011-287, § 10, 2011 N.C. Sess. Laws 1087, 1094.

After the Court of Appeals in this case interpreted the phrase “total loss of

wage-earning capacity” in a manner inconsistent with its plain meaning, the General

Assembly amended the law again to clarify that total loss of wage-earning capacity

means “the complete elimination of the capacity to earn any wages.” Current

Operations Appropriations Act of 2023, S.L. 2023-134, § 31.3.

That clarification controls in cases going forward, but its impact on this case

(and other cases pending at the time) led us to allow discretionary review. As

explained below, the General Assembly’s clarification was not necessary because it

reflects what the statute’s plain language meant all along: “total loss of wage-earning

capacity” in the 2011 amendment means the total loss of the employee’s personal

capacity to earn wages in any type of employment. We therefore modify the Court of

Appeals opinion to reject that court’s erroneous statutory interpretation but

otherwise affirm the court’s decision.

Facts and Procedural History

The facts of plaintiff Martin Sturdivant’s underlying workplace injury are not

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particularly relevant to the legal issues in this case. No one in this case disputes that

Sturdivant is an honest, hard-working person who spent most of his adult life

employed in jobs ranging from drywall laborer to poultry farm hand to industrial

machine operator.

In 2007, Sturdivant took a job as a corrections officer at the North Carolina

Department of Public Safety. Several years later, Sturdivant injured his back on the

job. The State agreed to accept responsibility for Sturdivant’s workplace injury and

paid temporary total disability payments though the workers’ compensation system.

To this day, Sturdivant still suffers from chronic back pain and that pain becomes

severe roughly one day each week.

When our State created its workers’ compensation system in the 1920s, the

law contained a provision limiting injured employees’ temporary total disability

payments to 400 weeks. See The North Carolina Workmen’s Compensation Act, ch.

120, § 29, 1929 N.C. Pub. Laws 117, 129.

In the early 1970s, the General Assembly removed that limitation. See An Act

to Amend the Workmen’s Compensation Act Regarding the Duration of Benefits, ch.

1308, § 1, 1973 N.C. Sess. Laws (2d Sess. 1974) 609, 609. As a result, for much of the

last fifty years, an employee who suffered a temporary total disability as defined in

the statutes could receive benefits indefinitely.

Over time, concern grew that our state’s extended disability benefits hurt the

ability to attract and retain businesses in the state. As one legislator explained in

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committee hearings contemplating further amendments, “North Carolina hurts its

ability to compete by turning our workers’ comp system into a retirement system.”

Workers’ Compensation: Putting North Carolina Back to Work, Hearing on H.B. 709

Before the S. Comm. on Insurance, 2011-2012 Sess. 338 (N.C. 2011).

Ultimately, in 2011, the General Assembly enacted a new law titled the “An

Act Protecting and Putting North Carolina Back to Work by Reforming the Workers’

Compensation Act.” See S.L. 2011-287. The act amended N.C.G.S. § 97-29 to create a

500-week limit on temporary total disability benefits. Id. § 10. After 500 weeks, an

employee could receive “extended compensation” only if the employee could “prove by

a preponderance of the evidence that the employee has sustained a total loss of wage-

earning capacity.” Id.

In 2020, as Sturdivant approached 500 weeks of total temporary disability

payments, he applied for extended compensation under N.C.G.S. § 97-29(c). The

Industrial Commission rejected his claim, concluding that Sturdivant had not

sustained a “total loss of wage-earning capacity” as required by the statute. In

reaching this decision, the Commission interpreted “total loss of wage-earning

capacity” to mean “a total loss of the ability to earn wages in any employment.”

Sturdivant appealed the Industrial Commission’s opinion and award to the

Court of Appeals. The Court of Appeals rejected the Commission’s interpretation of

section 97-29(c) and held that the phrase “total loss of wage-earning capacity” was

synonymous with “total disability” and thus incorporated a long line of court-created

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legal tests that went beyond merely assessing whether the employee had the ability

to earn wages in any employment. Sturdivant v. N.C. Dep’t of Pub. Safety, 288 N.C.

App. 470, 474–75 (2023).

The remaining portion of the Court of Appeals opinion was quite fractured. The

authoring judge held that Sturdivant was not entitled to extended benefits under

section 97-29(c) because Sturdivant failed to show that he sustained a “total

disability.” Id. at 476–79 (Dillon, J.). A second judge concurred “in result only”

without explaining the portions of the lead opinion with which the judge agreed or

disagreed. Id. at 480 (Stroud, J., concurring in result only). A third judge dissented

from the “total disability” analysis, reasoning that “the Commission did not make

specific findings of fact as to ‘the crucial questions necessary to support a conclusion’

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