Webb v. State of Delaware

CourtSuperior Court of Delaware
DecidedMay 9, 2024
DocketN23A-09-009 CEB
StatusPublished

This text of Webb v. State of Delaware (Webb v. State of Delaware) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Webb v. State of Delaware, (Del. Ct. App. 2024).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

JASON WEBB, ) ) Claimant-Below, Appellant, ) C.A. No. N23A-09-009 CEB ) ) v. ) ) STATE OF DELAWARE, ) ) Employer-Below, Appellee. )

ORDER

Submitted: February 29, 2024 Decided: May 9, 2024

Upon Consideration of Appellant’s Appeal of a Decision of the Industrial Accident Board AFFIRMED.

Joel H. Fredricks, Esquire, Nitsche and Fredericks, LLC, Wilmington, Delaware. Attorney for Claimant Below,Appellant.

Gregory P. Skolnik, Esquire, Heckler & Frabizzio, Wilmington, Delaware. Attorney for Employer-Below, Appellee.

BUTLER, R.J. This controversy is not really between the appellant, James Webb, and the

State of Delaware, but rather involves Webb’s attorney’s fees and who is/was

supposed to pay them. The Court finds that Webb’s attorney waived his claim to

attorney fees by settling the dispute without reservation of the issue and therefore

rules against the Appellant.

FACTS

Mr. Webb was an employee of the State of Delaware, working as a mechanic

for the Delaware State Police. He claimed a work-related injury and was out of work

for two separate periods, including spinal surgery and related medical expenses.

As a state employee, Webb received Short Term Disability (“STD”) benefits

while disengaged from his work. STD benefits are an employee benefit under the

State’s Disability Insurance Program, organized by the legislature and codified in

Chapter 52A of Title 29 of the Delaware Code. It is administered by the State

Employee Benefits Committee through the “Insurance Coverage Office” (“ICO”).1

This employee benefit is available at no cost to state employees who become

disabled, regardless of whether the disability is “work related.”

Webb also retained counsel to pursue a Worker’s Compensation claim which

is available to any employee who suffers a work-related injury. That program is

1 29 Del. C. § 5254. 1 administered through the Industrial Accident Board (“IAB”) and includes

administrative hearings and appeals, all codified in Chapter 23 of Title 19 of the

Delaware Code. Counsel and Webb agreed in a fee agreement that counsel would

receive a fee of 33 1/3% of the “total recovery from my employer or its insurance

carrier.”2

Appellant’s counsel duly filed a claim with the IAB, seeking Temporary Total

Disability (“TTD”). 3 The employer/State of Delaware/DSP retained counsel to

represent it and discovery proceeded as it does. Eventually, the Employer offered to

settle the dispute. The offer was 1) payment of $15,557 in back wages, 2) payment

of all medical expenses, and 3) “no separate and/or additional attorney fee.” 4 The

offer specifically noted that during this period Webb had received STD benefits for

his absences from work and that those wages were paid out of the State benefits plan.

“Per the usual procedure on such files,” the worker’s comp carrier agreed to pay out

the worker’s comp wage claim of $15,000, but it was to be escrowed in the

Appellant’s attorney’s escrow account until the ICO asserted its right to recoupment

of the STD benefits that had been paid to Webb. 5

2 Appellant’s App. to Opening Br. on Appeal Ex. A5, Trans. ID 71812893 (Jan. 16, 2024). All references to Appellant’s Appendix to Opening Brief on Appeal are referred to as “A ”. 3 While not entirely clear from the record, apparently Mr. Webb was back to work by this time. 4 A42. 5 A41. 2 Webb’s counsel confirmed acceptance of the terms via email.6 The funds were

duly deposited in Webb’s attorney’s escrow account. Along with the check came the

specific caveat noted in the original offer letter, this time in bold print and

underlined, that the funds were subject to an offset by the STD benefits that had been

paid by the State benefits office and was being tendered to counsel “pending

verification of the short term disability recoupment amount” and should not be

disbursed until the state benefits office was paid its recoupment from the settlement.

The claimant would be “permitted to keep any total disability amount left over after

satisfying the short term disability recoupment.” 7

Then came the bad news. The short-term disability payments to Mr. Webb

had totaled $15,486, virtually the entire amount recovered from the worker’s

compensation claim settlement. Instead of writing a check to the ICO as per the

settlement agreement, Appellant’s counsel sent the settlement check back to the

worker’s compensation carrier. According to counsel, “The insurance coverage

office took the position that it will not accommodate the attorney fee for the recovery

my office obtained.” He further asserted what he termed an attorney’s lien on the

$15,000 paid by the worker’s comp carrier to his client, saying “The attorney’s lien

6 Appendix to Employer-Below Appellee’s Answering Brief Ex. B1-2, Trans. ID 71953901 (Feb. 5, 2024). 7 A45. 3 is for one third of the total recovery. If this is distributed (by the compensation

carrier) to the Insurance Coverage Office for reimbursement of the total disability

payments without payment of the lien, I will file suit.”8

PROCEDURAL HISTORY

So, although the underlying dispute was settled, the attorney fee issue

remained contested. The worker’s compensation insurer filed a motion before the

IAB to enforce the settlement agreement as per the agreement with Appellant’s

counsel. In opposition, Appellant’s counsel took the position that he had achieved a

result benefitting the ICO (by return of the STD payments to the ICO) and he had

not been compensated for his efforts. And counsel said he knew that if the claimant

refused to make the recoupment to the ICO, the ICO would garnish the employee’s

wages to offset for the recovery of the worker’s compensation payments.9

The IAB held that:

[T]he settlement contract is clear. Claimant was to be paid a sum certain for total disability to be held in escrow, and once the short term disability recoupment amount was provided, claimant’s attorney was to repay same from the total disability payment, with claimant being entitled to the

8 A54. Read in context, the Court believes counsel meant to say, “short term disability payments, not total disability payment.” 9 A61-62. 4 remainder. No separate and/or additional medical witness or attorney fee was included in the agreement.10

Therefore, the Board ordered Appellant’s counsel to void the tendered

returned payment to the worker’s comp carrier and instead issue a check to the ICO

for the amount of recoupment as per the settlement agreement. Attorney fees were

not awarded.

Appellant’s counsel filed an appeal of the IAB’s Order to this Court,

complaining that the worker’s comp carrier had no standing, and the Board had no

jurisdiction to enforce the settlement agreement. The second argument is that the

worker’s comp carrier did not have a right to negotiate the STD recoupment.

ANALYSIS

A. The Board Acted Within Its Jurisdiction

Appellant argues first that the IAB “committed legal error” by granting the

employer’s request for declaratory relief because the employer lacked standing to

enforce the right of the ICO to a set off. While it is true that the employer sought a

declaratory judgment, it also moved to enforce of the settlement agreement—

accomplishing the same thing. What the employer got was an order of enforcement

of the settlement agreement. Whether the employer had standing to enforce the

10 A57.

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Bluebook (online)
Webb v. State of Delaware, Counsel Stack Legal Research, https://law.counselstack.com/opinion/webb-v-state-of-delaware-delsuperct-2024.