Claim of Burton v. ITT Continental Baking Co.
The claimant, a tractor-trailer driver for ITT Continental Baking Company, was injured and subsequently settled a third-party action without the explicit consent of the compensation carrier, Liberty Mutual Insurance Company. The Workers' Compensation Board ruled that the claimant forfeited further benefits due to this lack of consent, reversing an earlier hearing officer's decision. The claimant appealed, arguing that consent should be implied because Liberty Mutual also served as the liability insurer for the claimant in a separate personal injury action. The appellate court affirmed the Board's decision, finding that the specific facts did not establish implied consent, as there was no evidence of dual representation of the claimant by Liberty Mutual or its attorneys in both actions, nor knowledge of the settlement negotiations.