Porter v. State ex rel. Department of Workforce Services

Collateral estoppel is not given effect to an uncontested Wyoming Workers’ Compensation Division (Division) determination denying workers’ compensation benefits even when the denial is based on a finding that the employee did not suffer a compensable injury.Lea Porter, through her employer, submitted a report of injury to the Division, by which Porter reporter an injury to her left knee. The Division issued to Porter final determination informing her that it would not approve payments of benefits upon its determination that the injury was not a work-related injury. Porter did not object to the final determination or request a hearing but did object to a later final determination of the Division that denied payment of costs related to an MRI of her left knee. The Office of Administrative Hearings granted summary judgment for the Division, concluding that Porter could not challenge the denial of benefits for the MRI because she did not object to the Division’s earlier determination that her injury was not work related. The district court affirmed. The Supreme Court reversed, holding that Porter’s failure to object to the Division’s compensability determination did not preclude her objection to the Division’s final determination denying benefits to cover her MRI costs. View "Porter v. State ex rel. Department of Workforce Services" on Justia Law