Zenith Insurance Co. v. Ayala
Carmen Ayala sustained a lower back injury at work on January 28, 2006. Her initial diagnosis was later augmented to include lumbar radicular syndrome and L5-S1 spondylolisthesis (collectively, the "Lumbar Condition"). Zenith Insurance Company (Carrier) was notified of the injury on March 1, 2006, and despite having medical records of the Lumbar Condition by April 27, 2006, it did not dispute its compensability until July 28, 2006, 62 days after initial notice. A TWC hearing officer and appeals panel found that the Carrier waived its right to contest the compensability of the Lumbar Condition under Texas Labor Code Section 409.021 for failing to timely dispute it. The trial court granted summary judgment for Ayala, concluding the Carrier waived its right. The appellate court affirmed the trial court's judgment, rejecting the Carrier's argument that the Texas Administrative Code abrogates the waiver period for extent-of-injury disputes.