Claim of Marshall v. Savannah Sausage Corp.
This appeal concerns a decision by the Workers' Compensation Board disallowing a claimant's application for death benefits as untimely and denying counsel fees. James Marshall, a marketing consultant, sustained serious injuries in a 1977 motor vehicle accident and later died in 1981. His widow, the claimant, filed a death claim in 1984, which was deemed untimely by the Workers' Compensation Law Judge (WCLJ) and subsequently affirmed by the Board, as it was not filed within two years of Marshall's death. Additionally, the Board denied counsel fees, ruling that compensation benefits would not exceed the third-party settlement Marshall received, thus rendering further legal efforts futile. The appellate court affirmed the Board's decision, finding substantial evidence to support the untimely filing of the death claim and concurring that no counsel fees lien was applicable.