Service Lloyds Insurance Company v. American Alternative Insurance Corporation
This workers' compensation case involves an appeal by Service Lloyds Insurance Company against American Alternative Insurance Corporation (AAIC). The Texas Department of Insurance, Division of Workers' Compensation, ordered Service Lloyds to reimburse AAIC for benefits erroneously paid to an injured employee, Emmit Hines, for whom Service Lloyds was the liable carrier. Service Lloyds argued that a workers' compensation carrier cannot be a 'subclaimant' under Texas Labor Code section 409.009 and that the Division lacked jurisdiction over such a claim. The district court affirmed the Division's decision. The Court of Appeals affirmed the district court's judgment, concluding that a workers' compensation carrier can indeed be a subclaimant and the Division has jurisdiction to resolve such independently-raised subclaims.