FIRE AND CAS. INS. CO. OF CONN. v. Miranda
Javier Miranda, an appellee, was diagnosed with Hepatitis C after two minor work-related injuries and claimed it as an occupational disease. The Texas Worker's Compensation Commission (TWCC) and the trial court found that Fire & Casualty Insurance Company of Connecticut, the appellant, waived its right to contest compensability by failing to dispute the claim within the statutory period, based on previous case law. The Court of Appeals, however, noted that the relied-upon precedent, *Continental Cas. Co. v. Downs*, was overruled by *Southwestern Bell Tel. Co., L.P. v. Mitchell*. Crucially, the court distinguished between accidental injuries and occupational diseases regarding notice requirements. It ruled that Fire & Casualty's waiver for the initial laceration claim did not extend to the occupational disease claim, for which it had timely disputed after receiving notice of the Hepatitis C diagnosis. Consequently, the court reversed the trial court's judgment and rendered a take-nothing judgment in favor of Fire & Casualty, also dismissing Miranda's untimely cross-appeal for judicial review.