Texas Mutual Insurance Company v. Bertila Chicas, Individually and as Beneficiary of Santiago Chicas

CourtTexas Supreme Court
DecidedApril 5, 2019
Docket17-0501
StatusPublished

This text of Texas Mutual Insurance Company v. Bertila Chicas, Individually and as Beneficiary of Santiago Chicas (Texas Mutual Insurance Company v. Bertila Chicas, Individually and as Beneficiary of Santiago Chicas) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Texas Mutual Insurance Company v. Bertila Chicas, Individually and as Beneficiary of Santiago Chicas, (Tex. 2019).

Opinion

IN THE SUPREME COURT OF TEXAS

NO. 17-0501

TEXAS MUTUAL INSURANCE COMPANY, PETITIONER,

v.

BERTILA CHICAS, INDIVIDUALLY AND AS BENEFICIARY OF SANTIAGO CHICAS, DECEASED, RESPONDENT

ON PETITION FOR REVIEW FROM THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS

Argued January 22, 2019

JUSTICE BROWN delivered the opinion of the Court.

JUSTICE BUSBY did not participate in the decision.

In this case we consider whether the 45-day deadline to seek judicial review of a decision

by a Division of Workers’ Compensation appeals panel is jurisdictional. The trial court granted a

defendant’s plea to the jurisdiction and dismissed a judicial-review claim that had been filed after

the 45-day deadline. The court of appeals reversed, holding that while the 45-day deadline is

mandatory, it is not jurisdictional. For the reasons below, we agree with the court of appeals and

affirm.

I

On March 17, 2012, Santiago Chicas was doing yard work at the home of Peyton Waters,

Jr., when he fell from a ladder and sustained fatal injuries. Waters was the majority owner of Spartan Equipment and Supply, Inc., where Santiago was employed. Santiago’s wife, Bertila

Chicas (Chicas), sought workers’ compensation benefits from Spartan Equipment’s insurer, Texas

Mutual Insurance Company. After Texas Mutual disputed the claim, Chicas initiated

administrative proceedings to resolve the issue at the Texas Department of Insurance, Division of

Workers’ Compensation.

During the administrative proceedings, a hearing officer concluded after a contested-case

hearing that Santiago was not an employee of Spartan Equipment at the time of his injury and

therefore his injury was not compensable. Chicas appealed the hearing officer’s determinations to

an appeals panel. On January 5, 2015, the Division notified Chicas that after review by the panel,

the hearing officer’s decision and order was final. The notice also stated, consistent with Texas

Labor Code section 410.252(a), that “[i]f you are not satisfied with this decision and desire to have

the dispute resolved in court, then you must file a lawsuit in the appropriate district court not later

than the 45th day after the date on which the Division of Workers’ Compensation mailed the parties

the decision.”

Meanwhile, while the administrative proceedings were still pending, Chicas had filed a

wrongful-death suit in probate court against Spartan Equipment and others. On February 4, 2015,

well within the 45-day deadline to seek review of the appeals-panel decision, Chicas amended her

probate-court pleadings to add Texas Mutual as a defendant, seeking judicial review of the

administrative decision. Six months later, Texas Mutual filed a plea to the jurisdiction and argued

that the probate court could not exercise jurisdiction over a judicial review that had no relationship

to the administration of an estate. The probate court granted Texas Mutual’s plea.

2 Twelve days after the probate court dismissed her claims, Chicas again filed suit against

Texas Mutual but in district court, “seek[ing] judicial review of the Appeals Panel Decision.”

Texas Mutual filed another plea to the jurisdiction, asserting (1) that the 45-day deadline to seek

judicial review of an appeals-panel decision is jurisdictional and (2) because Chicas filed suit in

the district court after the deadline had passed, that court lacked jurisdiction. The district court

granted Texas Mutual’s plea to the jurisdiction and dismissed Chicas’s claims against it in their

entirety.

Chicas appealed. The court of appeals reversed, holding that the 45-day deadline for filing

judicial-review claims in section 410.252(a) is not a jurisdictional statutory prerequisite.

522 S.W.3d 67, 68 (Tex. App.―Houston [1st Dist.] 2017). Therefore, it concluded that the trial

court erred in granting Texas Mutual’s plea to the jurisdiction. Id. at 74–75. The court did not

address whether Chicas’s claims were timely, noting that the limitations issue was properly left

for resolution by way of a motion for summary judgment. Id. at 75 n.4. We granted Texas Mutual’s

petition for review. It is undisputed that Chicas filed suit in district court after the 45-day deadline

had passed. So, we must determine whether Chicas’s failure to file suit before the deadline

deprived the district court of jurisdiction. See City of DeSoto v. White, 288 S.W.3d 389, 395 (Tex.

2009) (“The failure of a jurisdictional requirement deprives the court of the power to act . . . .”

(quoting Univ. of Tex. Sw. Med. Ctr. at Dall. v. Loutzenhiser, 140 S.W.3d 351, 359 (Tex. 2004)).

3 II

A

The parties agree the 45-day deadline to seek judicial review of an appeals-panel decision

is mandatory, but “just because a statutory requirement is mandatory does not mean that

compliance with it is jurisdictional.” Id. at 395 (quoting Albertson’s, Inc. v. Sinclair, 984 S.W.2d

958, 961 (Tex. 1999)). Nearly a century ago, we held that where a cause of action is derived from

a statute, including a suit challenging a workers’ compensation award, “strict compliance with all

statutory prerequisites is necessary to vest a trial court with jurisdiction.” Prairie View A & M

Univ. v. Chatha, 381 S.W.3d 500, 510 (Tex. 2012) (citing Mingus v. Wadley, 285 S.W. 1084, 1087

(Tex. 1926)). This remained the law for decades and, consistent with Mingus, multiple courts of

appeals treated the statutory deadline for seeking judicial review of an appeals-panel decision as

mandatory and jurisdictional. See, e.g., Tex. Workers’ Comp. Comm’n v. Hartford Accident &

Indem. Co., 952 S.W.2d 949, 952 (Tex. App.—Corpus Christi–Edinburg 1997, pet. denied);

Adkins v. Ector Cty. Indep. Sch. Dist., 969 S.W.2d 142, 143 (Tex. App.—El Paso 1998), pet.

denied, 989 S.W.2d 363 (Tex. 1999) (per curiam); Morales v. Emp’rs Cas. Co., 897 S.W.2d 866,

868 (Tex. App.—San Antonio 1995, writ denied).

But in Dubai Petroleum Co. v. Kazi, 12 S.W.3d 71, 76 (Tex. 2000), we identified concerns

with the approach to subject-matter jurisdiction that we set out in Mingus. We recognized that

although Mingus was consistent with the dominant approach at the time it was decided, “the

modern direction of policy is to reduce the vulnerability of final judgments to attack on the ground

that the tribunal lacked subject matter jurisdiction.” Id. at 76 (quoting RESTATEMENT (SECOND) OF

4 JUDGMENTS § 11 cmt. e, at 113 (1982)). We overruled Mingus “to the extent that it characterized

the plaintiff’s failure to establish a statutory prerequisite as jurisdictional.” Id.

Following Dubai, in In re United Services Auto Ass’n, 307 S.W.3d 299, 304 (Tex. 2010)

[hereafter, USAA], we analyzed another statutory deadline for filing suit to determine whether it

was jurisdictional.

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