Texas Workers' Compensation Commission, the Subsequent Injury Fund, and Todd Brown in His Official Capacity as Executive Director of the Texas Workers' Compensation Commission v. the City of Bridge City, Texas, and the Texas Municipal League Intergovernmental Risk Pool

CourtCourt of Appeals of Texas
DecidedMay 24, 1995
Docket03-94-00124-CV
StatusPublished

This text of Texas Workers' Compensation Commission, the Subsequent Injury Fund, and Todd Brown in His Official Capacity as Executive Director of the Texas Workers' Compensation Commission v. the City of Bridge City, Texas, and the Texas Municipal League Intergovernmental Risk Pool (Texas Workers' Compensation Commission, the Subsequent Injury Fund, and Todd Brown in His Official Capacity as Executive Director of the Texas Workers' Compensation Commission v. the City of Bridge City, Texas, and the Texas Municipal League Intergovernmental Risk Pool) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Texas Workers' Compensation Commission, the Subsequent Injury Fund, and Todd Brown in His Official Capacity as Executive Director of the Texas Workers' Compensation Commission v. the City of Bridge City, Texas, and the Texas Municipal League Intergovernmental Risk Pool, (Tex. Ct. App. 1995).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN



NO. 03-94-00124-CV



Texas Workers' Compensation Commission, the Subsequent Injury Fund,

and Todd Brown in His Official Capacity as Executive Director of

the Texas Workers' Compensation Commission, Appellants



v.



The City of Bridge City, Texas, and the Texas Municipal League

Intergovernmental Risk Pool, Appellees



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 126TH JUDICIAL DISTRICT

NO. 92-14599, HONORABLE JOSEPH H. HART, JUDGE PRESIDING



The Texas Workers' Compensation Commission, its executive director Todd Brown, and the Subsequent Injury Fund (1) appeal from a declaratory judgment and permanent injunction ordered by the trial court in a suit brought by the City of Bridge City, Texas, and the Texas Municipal League Intergovernmental Risk Pool ("TML"). We will reverse the trial-court judgment, dissolve the injunction, and render the declaratory judgment we believe the trial court should have rendered. Tex. R. App. P. 81(c).



THE CONTROVERSY

Under the Texas Workers' Compensation Act, the legislature established a four-tier system for the determination of claims. Subchapter B provides first for the informal resolution of claims through a non-adversarial conference conducted by a "benefit review officer" who may render an interlocutory order that benefits be paid or that they not be paid. The informal conference is a prerequisite to any further proceeding toward resolution of the claim. See Tex. Lab. Code Ann. §§ 410.021-.024 (West 1995) ("Act"). If issues remain unresolved after the conference, the parties may agree to resolve the claim by arbitration under Subchapter C; failing agreement in that regard, a party may elect to determine the claim by a contested-case proceeding under the provisions of Subchapter D. Id. §§ 410.101-.121 (arbitration); §§ 410.151-.169 (contested case). The third tier is established in Subchapter E, providing for an administrative appeal from the hearing officer's contested-case decision to an appeals panel. Id. §§ 410.201-.208. Review outside the Commission is authorized in Subchapter F, establishing a cause of action for judicial review of the appeals-panel decision or the hearing officer's decision if the appeals panel fails timely to render a decision. Id. §§ 410.251-.256.

The insurance carrier must commence making any payments ordered by the benefit-review officer. If the order is reversed or modified after arbitration or the contested-case proceeding, however, the carrier is entitled to reimbursement from the subsequent-injury fund for any overpayment. Id. § 410.025(c). And if the appeals-panel decision affirms the carrier's duty to pay, but the decision is finally modified or reversed by a reviewing court, the carrier is entitled to reimbursement from the fund for any overpayment. Id. § 410.205(c). Apparently, these provisions are construed so that the carrier is not entitled to recover any overpayment made during the period between the date of the contested-case decision requiring payment and the date of the appeals-panel decision affirming that decision, even though the latter decision is reversed on judicial review.

Threatened by administrative penalties if they do not pay benefits during the only period when reimbursement is not expressly secured by the statutory scheme, the City (a self-insurer) and TML sued for declaratory judgment that the Act is unconstitutional. (2) The trial court held the scheme unconstitutional on the grounds indicated below and issued a permanent injunction against enforcement of the scheme. The Commission, its executive director, and the Subsequent Injury Fund appeal.



THE TRIAL-COURT JUDGMENT

The trial court held the statutory scheme unconstitutional on the following grounds:



1. The requirement of immediate payment of a decision and order of benefit contested case hearing officer during the pendency of an appeal to the Appeals Panel [Tex. Labor Code Ann. § 410.169] . . . and Commission Rule 142.16(e) through (g) violates Article 1, § 19, of the Texas Constitution because it limits the City's property rights in a fundamentally unfair manner.



2. This pre-payment without reimbursement scheme violates Article 1, § 13, of the Texas Constitution because it is an unreasonable interference with access to the courts. The scheme imposes unreasonable financial barriers on court access and fails to provide a meaningful access and fails to provide a meaningful legal remedy to the Plaintiffs.



3. Article 1, § 17, of the Texas Constitution is also violated by this administrative scheme. The Plaintiffs hold the disputed funds in trust for the citizens of the City of Bridge City, Texas and the administrative requirement that the City's funds be forfeited prior to a final decision, without hope of recovery, is a taking in violation of the Texas Constitution.



4. The statutory scheme also violates Article 3, § 61, because it fails to provide suitable laws for the administration of workers' compensation insurance administration.



DISCUSSION AND HOLDINGS

I.

In their first point of error, appellants contend the trial court erred because a municipal corporation is not a "citizen" or "person" within the meaning of the bill of rights constituting Article I of the state constitution, specifically sections 13, 17, and 19 upon which the trial court based its declaration that the statutory scheme is unconstitutional. Tex. Const. art. I, §§ 13, 17, 19. We believe the trial court erred. Municipal corporations and other government subdivisions derive their existence and powers from legislative enactments and are subject to legislative control and supremacy. Consequently, they cannot use the sword of the due-process-of-law and other provisions of Article I to invalidate the laws that govern them. See McGregor v. Clawson, 506 S.W.2d 922, 929 (Tex. Civ. App.--Waco 1974, no writ); Harris County v. Dowlearn, 489 S.W.2d 140, 145 (Tex. Civ. App.--Houston [14th Dist.] 1973, writ ref'd n.r.e.); Boyett v. Calvert, 467 S.W.2d 205, 210 (Tex. Civ. App.--Austin 1971, writ ref'd n.r.e.), appeal dismissed for want of federal question sub nom., Anderson v. Calvert, 405 U.S. 1035 (1972); see generally 2 Eugene McQuillin, Municipal Corporations § 4.20 (3d ed. 1988).

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Texas Workers' Compensation Commission, the Subsequent Injury Fund, and Todd Brown in His Official Capacity as Executive Director of the Texas Workers' Compensation Commission v. the City of Bridge City, Texas, and the Texas Municipal League Intergovernmental Risk Pool, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-workers-compensation-commission-the-subsequent-injury-fund-and-texapp-1995.