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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Texas Municipal League Intergovernmental Risk Pool v. Texas Workers' Compensation Commission

The Texas Municipal League Intergovernmental Risk Pool, representing numerous self-insured political subdivisions, challenged specific sections of the Texas Labor Code and associated administrative rules. These provisions require workers' compensation insurance carriers, including the Risk Pool, to pay death benefits (in cases where no legal beneficiary exists) into the Subsequent Injury Fund. This fund is then used to compensate workers who sustain second injuries and to reimburse other insurance carriers. The Risk Pool contended that these mandates violate Article III, Section 52(a) of the Texas Constitution, which restricts political subdivisions from lending credit or granting public money to individuals or private corporations without a pre-existing legal obligation. While the trial court initially agreed with the Risk Pool, the court of appeals reversed this decision, and the Supreme Court subsequently affirmed that reversal. Justice Owen dissents from this judgment, arguing that the challenged funding mechanism is unconstitutional, as it compels political subdivisions to fund compensation for non-employees and to reimburse private carriers, citing the precedent set in *City of Tyler v. Texas Employers’ Insurance Association*.

Texas ConstitutionPolitical SubdivisionsWorkers' CompensationSubsequent Injury FundSelf-InsuranceDeath BenefitsConstitutional LawPublic FundsIntergovernmental Risk PoolStatutory Interpretation
References
4
Case No. MISSING
Regular Panel Decision

STATE OFFICE OF RISK MANAGEMENT v. Allen

Jerome D. Allen, a juvenile correction officer, was injured in March 2004 during employment. The State Office of Risk Management (SORM), administrator of workers' compensation, accepted head and shoulder injuries but disputed a lower back injury. A contested case hearing and subsequent appeals panel both found Allen's compensable injury extended to his lower back. SORM sought judicial review, and a jury also found in Allen's favor. SORM appealed, arguing the trial court erred in admitting hearsay evidence (a hearing officer's decision and order) and that the verdict was factually insufficient. The appellate court found any error in admitting the decision and order harmless, as the evidence was cumulative and also presented through SORM's own expert witness. The court also found the evidence factually sufficient to support the jury's verdict, noting Allen's testimony about new back pain symptoms post-injury and the compensability of aggravating a pre-existing condition. The trial court's judgment was affirmed.

Workers' CompensationAppellate ReviewHearsay EvidenceFactual SufficiencyJury VerdictCompensable InjuryLower Back InjuryPre-existing ConditionMedical RecordsChiropractor Testimony
References
6
Case No. MISSING
Regular Panel Decision
Apr 01, 2009

STATE OFFICE OF RISK MANAGEMENT v. Martinez

This is a workers’ compensation case where the State Office of Risk Management appealed a trial court’s pre-trial directed verdict in favor of Edna A. Martinez, an employee of the Texas Department of Protective and Regulatory Services. Martinez sustained injuries while working from home and her workers' compensation claim was initially denied. The appeals panel sided with Martinez, leading the State Office of Risk Management to seek judicial review. The trial court granted a pre-trial directed verdict for Martinez. The appellate court found that the trial court erred in granting the pre-trial directed verdict because it prematurely denied the State Office of Risk Management the right to present evidence and cross-examine Martinez. The court also determined that the "Downs waiver" argument, used by Martinez, was no longer viable. Therefore, the judgment of the trial court was reversed and the cause was remanded for further proceedings.

Workers' CompensationDirected VerdictSummary JudgmentCourse and Scope of EmploymentPremature RulingEvidentiary StandardsAppellate ReviewTexas Labor CodeDowns WaiverCredibility of Witness
References
11
Case No. 15-25-00134-CV
Regular Panel Decision
Jul 30, 2025

Texas Association of School Boards Risk Management Fund // Southwest Texas Junior College v. Southwest Texas Junior College // Cross-Appellee, Texas Association of School Boards Risk Management Fund

This case involves an intergovernmental contract dispute between the Texas Association of School Boards Risk Management Fund (Appellant) and Southwest Texas Junior College (Appellee). The College is seeking replacement cost value benefits under a self-insurance contract for property damage allegedly sustained during an April 2021 hailstorm. The College claims a waiver of the Fund’s governmental immunity under TEX. LOC. GOV’T CODE § 271.152, asserting equitable theories of waiver and unconscionability, and intentional torts of fraud and bad faith to expand coverage beyond the express terms of the agreement. The Fund argued that its governmental immunity had not been waived for these claims and damages, emphasizing that statutory waivers are to be narrowly construed. The trial court partially granted the Fund's jurisdictional plea, dismissing claims for exemplary, consequential, or treble damages, but denied the plea regarding the College's equitable and intentional tort theories, viewing them as defensive in nature. The Fund appeals this partial denial, arguing that the Act's narrow immunity waiver does not extend to these theories which attempt to create coverage where none explicitly exists in the written contract.

Governmental ImmunityContract DisputeSelf-Insurance PoolRisk ManagementEquitable DoctrinesIntentional TortsWaiverUnconscionabilityTexas LawAppellate Review
References
14
Case No. 03-06-00480-CV
Regular Panel Decision
May 18, 2007

Texas Council Risk Management Fund, as Subrogee for Michael Stary v. Evelyn Caswell and Allstate Insurance Companies

The Texas Council Risk Management Fund appealed a judgment that it take nothing on its subrogation claim against Evelyn Caswell. The trial court had found the Fund's claim barred by a pre-trial release signed by Michael Stary, the Fund's insured, reasoning that as a subrogee, the Fund stepped into Stary's shoes and was subject to available defenses. The Court of Appeals reversed, holding that a settlement between an insured and a third-party tortfeasor after the insurer has paid a claim does not extinguish the insurer's subrogation rights. However, the court ruled that the awarded damages must be reduced by the amount Allstate Insurance Companies had already paid to the Fund. The court rendered judgment for the Fund against Caswell in the amount of $10,116.00 and remanded the case for a ruling on pre- and post-judgment interest.

Subrogation ClaimWorkers' CompensationInsurance LawThird-Party TortfeasorSettlement AgreementRelease of ClaimsMotor Vehicle AccidentAppellate ReviewDamages AwardElection of Remedies
References
12
Case No. FRE 0159318
Regular
Nov 05, 2007

ROGELIO RODRIGUEZ vs. AMERICAN GRAPE HARVESTERS, STATE COMPENSATION INSURANCE FUND

This case involves Rogelio Rodriguez seeking workers' compensation for injuries to his right arm and psyche. The defendant, American Grape Harvesters and State Compensation Insurance Fund, petitioned for reconsideration of a 100% permanent disability award, arguing insufficient evidence and failure to consider pre-existing factors. The Workers' Compensation Appeals Board denied reconsideration, adopting the judge's report which found the evidence supported the 100% award and that pre-existing factors were properly addressed.

Workers' Compensation Appeals BoardReconsideration DeniedPermanent DisabilityVocational RehabilitationOrthopedic InjuryPsychiatric DisabilityAgreed Medical ExaminerQualified Medical EvaluatorApportionmentNon-Industrial Factors
References
7
Case No. ADJ2728533 (VNO 0389518) ADJ2462440 (VNO 0193190)
Regular
Jul 27, 2015

ALICIA VALENZUELA vs. LEATHERCRAFT TECHNOLOGIES dba ALEXANDER HANDBAGS, CYPRESS INSURANCE COMPANY, c/o BERKSHIRE HATHAWAY HOMESTATE CO., CONSTITUTION STATE SERVICE CO.

This case concerns a defendant's petition for reconsideration of an arbitrator's decision regarding a lien claim for medical treatment reimbursement. The arbitrator found the defendant responsible for 80% of low back treatment costs but not kidney or psyche treatment, despite the applicant's injuries being attributed to "pre-existing factors." The defendant argued it was denied due process and that the arbitrator erred in terminating its lien rights based on stipulations. The Board denied reconsideration, finding the defendant had a fair hearing and failed to meet its burden of proof that the "pre-existing factors" included a prior 1987 injury, with medical evidence supporting the arbitrator's conclusion.

Workers' Compensation Appeals BoardPetition for ReconsiderationLienMedical TreatmentPre-existing FactorsCumulative InjurySpecific InjuryDue ProcessFair HearingBurden of Proof
References
12
Case No. 525240
Regular Panel Decision
May 24, 2018

Matter of Pickerd v. Paragon Envtl. Constr., Inc.

The Appellate Division, Third Department, affirmed a Workers' Compensation Board decision which found that the decedent's death was causally related to his employment and awarded workers' compensation death benefits to claimant Barbara Pickerd. Decedent suffered a fatal myocardial infarction while assisting a coworker with the removal of a gasoline tank. The employer and its carrier appealed, arguing against the causal connection. The court found that substantial evidence, including medical testimony, supported the Board's determination that decedent's work activities were significant precipitating factors, despite pre-existing cardiac risk factors. The Board was within its province to resolve conflicting medical evidence in favor of the claimant.

myocardial infarctionworkers' compensationdeath benefitscausal relationemployment injurypre-existing conditionmedical testimonyconflicting evidenceappellate reviewheart attack
References
7
Case No. MISSING
Regular Panel Decision

Helton v. Food Lion, Inc.

The plaintiff, a produce supervisor for Food Lion, Inc., suffered a heart attack four days after an abrasive confrontation with his new supervisor, Mr. Anderson. The trial court denied worker's compensation benefits, finding that the heart attack did not arise out of and in the course of employment. Medical testimony indicated job stress was a contributing factor, but also noted the plaintiff's pre-existing severe arteriosclerotic heart disease and other risk factors. The Supreme Court of Tennessee affirmed the trial court's decision, concluding that the stress, occurring four days prior to the heart attack, was of a general nature and not the "acute, sudden, or unexpected emotional stress directly attributable to employment" required for a compensable accident.

Worker's CompensationHeart AttackEmotional StressCausationPre-existing ConditionScope of EmploymentMedical EvidenceJob-related StressDenial of BenefitsTennessee Supreme Court
References
5
Case No. 07-05-0268-CV
Regular Panel Decision
Apr 11, 2006

State Office of Risk Management v. Rachel Herrera and Texas Municipal League Intergovernmental Risk Pool

The State Office of Risk Management (SORM) appealed the dismissal of its attempt to judicially review a Texas Worker’s Compensation Commission appeals panel ruling. The trial court had dismissed SORM's petition for lack of jurisdiction, asserting it was not timely filed within 30 days. SORM argued that the dispute concerned compensability, which allowed for a 40-day filing period under the Labor Code. The Court of Appeals determined that the core issue of identifying the responsible employer for death benefits, thereby defining the course and scope of employment, constituted a matter of compensability. Consequently, SORM had 40 days to file. The appellate court reversed the trial court’s order of dismissal and remanded the case for further proceedings.

Worker's CompensationJudicial ReviewJurisdictionTimelinessCompensabilityCourse and Scope of EmploymentDeath BenefitsTexas Labor CodeGovernment CodeAppeals Court
References
3
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