Toole ex rel. Professional Liability Fund v. EBI Companies

815 P.2d 216, 108 Or. App. 57, 1991 Ore. App. LEXIS 1058
CourtCourt of Appeals of Oregon
DecidedJuly 3, 1991
DocketWCB No. TP-89003; CA A62038; WCB No. TP-89022; CA A62117; WCB No. TP-89010; CA A62386
StatusPublished
Cited by2 cases

This text of 815 P.2d 216 (Toole ex rel. Professional Liability Fund v. EBI Companies) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Toole ex rel. Professional Liability Fund v. EBI Companies, 815 P.2d 216, 108 Or. App. 57, 1991 Ore. App. LEXIS 1058 (Or. Ct. App. 1991).

Opinion

JOSEPH, C. J.

In these consolidated cases, claimants had sustained compensable injuries and received workers’ compensation benefits. Each claimant pursued a separate personal injury claim against a third party who was alleged to have negligently caused the compensable injury. ORS 656.154; ORS 656.578.1 In each case, claimant lost the third party claim or received only a partial recovery. Claimants then asserted claims against their attorneys, alleging that the attorneys’ negligence prevented appropriate recoveries on their third party claims. Those malpractice claims were settled without an admission of liability, and a payment was made to each claimant by the Oregon State Bar Professional Liability Fund (PLF).

After the malpractice settlements, EBI Companies and Port of Portland (insurers), who are the paying agents under the third party recovery statutes,2 filed petitions with the Workers’ Compensation Board, asserting liens against the settlement proceeds under ORS 656.5803 in each case and requesting to be paid a share of the proceeds or that each [61]*61settlement be declared void for lack of the paying agent’s written approval.4 On behalf of each claimant, PLF contested the Board’s jurisdiction to rule on the petitions. The Board’s order in each case held: (1) It had jurisdiction to decide a dispute over the distribution of the settlement proceeds; (2) the paying agent’s lien attached to the settlement proceeds; and (3) each settlement was void for lack of the paying agent’s approval. PLF seeks reversal of the Board’s decision that it has jurisdiction to decide this issue or, in the alternative, reversal of the decision that a paying agent’s lien can attach to a legal malpractice action recovery.

PLF argues that, under the third party recovery statutes, the Board had no jurisdiction over the settlement proceeds. It contends that the statutes expressly limit the Board’s jurisdiction only to distribution of settlements between an injured worker and a third party who caused the compensable injury. See ORS 656.154; ORS 656.578; ORS 656.580; ORS 656.583; ORS 656.587; ORS 656.591. After oral argument in this court, PLF filed a memorandum citing SAIF v. Wright, 102 Or App 598, 795 P2d 604, mod 104 Or App 322, 801 P2d 848 (1990), rev allowed 311 Or 60 (1991), for the proposition that the Board does not have authority either to rule on insurers’ petitions for distribution or to declare the settlements between claimants and PLF’s insureds void.

[62]*62Insurers argue that, according to case law, the Board has jurisdiction over all third party lien disputes. They rely on EBI Companies v. Cooper, 100 Or App 246, 249, 785 P2d 380 (1990); Harvey v. Lou Surcamp Logging, 100 Or App 227, 229 n 1, 785 P2d 383 (1990); and Shipley v. SAIF, 79 Or App 149, 152, 718 P2d 757, rev den 301 Or 338 (1986).

PLF misconstrues Wright. In that case, SAIF had denied a claim on the ground that the claimant was not a “subject worker” of any of three non-complying employers. The claimant appealed to the Board. While awaiting the Board’s decision, the claimant and the third party that had caused the compensable injury5 settled their case. The Board decided that the claimant was a “subject worker” of one of the employers, and SAIF began processing the claim. SAIF learned of the settlement only after the settlement proceeds had already been distributed to the claimant and his creditors. SAIF nonetheless moved the Board for an

“order requiring [claimant] and his attorney * * * to distribute to SAIF Corporation the sum of $36,324.24 as its [ORS 656.593] share of the (unapproved) third party settlement made in this matter.” 102 Or App at 600.

The Board denied SAIF’s motion on the ground that SAIF was not the “paying agency” when the claimant settled his third party action. On review, we held that, although the Board had jurisdiction over SAIF’s motion, it did not have the authority to grant the specific relief sought.6 We said that, whatever tribunal might have authority to adjudicate the issues necessary for final resolution of a paying agent’s claim in such circumstances, it is not the Workers’ Compensation Board. 102 Or App at 601.

[63]*63This case is factually different from Wright, and the issues are different. The applicability of the distribution statutes is disputed, because the proceeds are due to attorney malpractice, rather than to infliction of physical injury. The question is: Does the Board have the authority to decide whether the proceeds of a settlement of a particular type of claim are distributable under the Workers’ Compensation Law?

Numerous cases have acknowledged, or presumed, that the Board had the authority to decide various questions relating to proceeds sought to be distributed. In Allen v. American Hardwoods, 102 Or App 562, 795 P2d 592, rev den 310 Or 547 (1990), an Oregon workers’ compensation insurer sought distribution of settlement proceeds obtained from a Michigan company by a deceased worker’s beneficiary and an injured worker, both of whom were Oregon residents. Michigan law did not allow reimbursement to a workers’ compensation insurer if only noneconomic loss had been recovered, which was true of both settlements involved. The Oregon insurer petitioned the Board for an order declaring its lien against the Michigan settlement proceeds valid. We agreed with the Board’s choice of law analysis and affirmed its conclusion that Oregon law governs the validity of an Oregon insurer’s liens on another state’s third party settlement.

In Shipley v. SAIF, supra, the claimant sought review of a Board order that held that his recovery from a third party’s insurance company, arising out of an earlier judgment against the company’s insured for injuring the plaintiff, was subject to a lien under ORS 656.593(1). We upheld the Board without discussing its authority to decide the issue. In EBI Companies v. Cooper, supra, we decided that the Board had the authority to decide whether the claimant’s election to assign his third party claim to the compensation carrier was obtained fraudulently and whether it could redistribute the proceeds of a settlement negotiated by the insurer:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Aagesen v. SAIF Corp.
868 P.2d 2 (Court of Appeals of Oregon, 1994)
Toole v. EBI Companies
838 P.2d 60 (Oregon Supreme Court, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
815 P.2d 216, 108 Or. App. 57, 1991 Ore. App. LEXIS 1058, Counsel Stack Legal Research, https://law.counselstack.com/opinion/toole-ex-rel-professional-liability-fund-v-ebi-companies-orctapp-1991.