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

Case No. 01-15-00147-CV
Regular Panel Decision
Apr 06, 2015

Metropolitan Insurance and Annuity Company and Metropolitan Life Insurance Company v. Peachtree Settlement Funding, LLC

This case involves an appeal by Metropolitan Life Insurance Company and Metropolitan Insurance & Annuity Company (Appellants) against Peachtree Settlement Funding, LLC and Sara Swain (Appellees) regarding a trial court's approval of a structured settlement payment rights transfer. Sara Swain, the payee, sought to transfer partial monthly payments to Peachtree, leading to a "Servicing Arrangement" approved by the trial court. This arrangement allowed Peachtree to receive the full monthly payments, retain its assigned portion, and remit the remainder to Swain, without requiring MetLife to directly divide payments. MetLife challenged this, asserting the arrangement improperly modified contracts, contravened the Texas Transfer Statute, and imposed an involuntary business relationship. The Appellee's brief argues for the affirmation of the trial court's decision, emphasizing the legality of the servicing arrangement under Texas's principles of contract assignability and principal-agency law, and affirming the transfer as being in Swain's best interest.

Structured SettlementPayment Rights TransferServicing ArrangementContract AssignabilityPrincipal-Agency LawBest Interest DeterminationAppellate ReviewTexas Transfer StatuteLegal PrecedentAnnuity Issuer Obligations
References
68
Case No. 2018 NY Slip Op 05037 [163 AD3d 558]
Regular Panel Decision
Jul 05, 2018

Matter of Empire State Transp. Workers' Compensation Trust v. Special Funds Conservation Comm.

This case concerns a proceeding initiated by Empire State Transportation Workers' Compensation Trust for judicial approval of a settlement, nunc pro tunc, against the Special Funds Conservation Committee. The underlying issue stemmed from the Trust's failure to obtain consent from the Special Funds for a claimant's personal injury settlement, which led the Workers' Compensation Board to find a waiver of reimbursement rights. After an initial denial by the Supreme Court, the Appellate Division reversed and remitted, affirming the court's discretion in compelling such consent. Upon remittitur, the Supreme Court granted the petition, directing the Special Funds to provide nunc pro tunc consent. The Appellate Division affirmed this subsequent order, concluding that the settlement was reasonable, the delay was adequately explained, and no prejudice was demonstrated against the Special Disability Fund.

Workers' CompensationNunc Pro TuncSettlement ApprovalPersonal Injury ActionSpecial Funds Conservation CommitteeAppellate DiscretionReimbursement WaiverJudicial ReviewAppellate PracticeNassau County
References
14
Case No. 2024 NY Slip Op 06200
Regular Panel Decision
Dec 11, 2024

Matter of NYAHSA Servs., Inc. v. Special Funds Group

This case concerns an appeal by NYAHSA Services, Inc., the workers' compensation insurance carrier for St. Patrick's Nursing Home, from an order denying its petition for judicial approval of a personal injury settlement nunc pro tunc. The underlying matter involved Karen DiNoia, who sustained injuries in 2001 during employment and settled a third-party personal injury action in 2005 for $400,000. Although NYAHSA consented, the Special Funds Group's consent was not obtained at the time, which is crucial for the carrier to be reimbursed from the Special Disability Fund. The Supreme Court dismissed the petition, citing a lack of required documentation. However, the Appellate Division, Second Department, reversed the decision, finding that the settlement was reasonable, the delay in seeking judicial relief was not the petitioner's fault, and the Special Funds Group was not prejudiced, thus granting the petition.

Nunc Pro TuncPersonal Injury SettlementJudicial ApprovalAppellate ReviewSpecial Disability FundInsurance Carrier ReimbursementSupreme Court DiscretionDelayPrejudiceReasonableness of Settlement
References
10
Case No. MISSING
Regular Panel Decision

Iron Workers Locals 40, 361 & 417 Health Fund v. Dinnigan

The case involves a dispute between the Iron Workers Locals 40, 361, & 417 Health Fund and Robert Dinnigan, Amanda C. Dinnigan Supplemental Needs Irrevocable Trust, and their attorney regarding reimbursement of medical expenses. The Health Fund sought nearly $1.7 million paid for Amanda Dinnigan's severe injuries from a third-party tortfeasor settlement. Defendants argued against reimbursement, citing state anti-subrogation laws and the "made-whole" doctrine. The court ruled that the Health Fund was self-insured, thus preempting state law, and that the 2008 SPD, which rejected the made-whole doctrine, applied to most expenses. Ultimately, the court ordered judgment for the Plaintiff in the amount of $1,292,278, having reduced the claim by 25% to account for the Defendants' attorneys' fees and expenses in securing the original settlement.

ERISAEmployee BenefitsHealth Fund ReimbursementSubrogationEquitable ReliefSelf-Insured PlanMade-Whole DoctrinePersonal Injury SettlementSupplemental Needs TrustAttorneys' Fees
References
32
Case No. MISSING
Regular Panel Decision

Rapid Settlements Ltd. v. SSC Settlements, LLC

This case involves an appeal and mandamus proceeding filed by Rapid Settlements, Ltd. and Rapid Management Corporation (Rapid) against SSC Settlements, L.L.C. and Stone Street Capital, Inc. (SSC). Rapid challenged a final summary judgment related to the transfer of structured settlement payments from William Prante. Rapid sought to stay litigation pending arbitration, arguing the dispute with SSC fell under an arbitration clause in their agreement with Prante, which also included a right of first refusal and a security interest. The appellate court denied the mandamus petition, vacated the trial court's denial of Rapid's motion to stay, and reversed parts of the summary judgment concerning Rapid's security interest and right of first refusal. The court affirmed the trial court's award of attorney's fees to SSC and its injunction preventing Rapid from compelling SSC to arbitrate.

Arbitration AgreementMandamus ProceedingSummary JudgmentDeclaratory JudgmentStructured SettlementRight of First RefusalSecurity InterestEquitable EstoppelDirect Benefits EstoppelContract Law
References
42
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. MISSING
Regular Panel Decision

Trustees of the American Federation of Musicians & Employers' Pension Fund v. Steven Scott Enterprises, Inc.

Plaintiffs, the Trustees of the American Federation of Musicians and Employers’ Pension Fund, brought suit against Steven Scott Enterprises, Inc. seeking an audit of payroll records from 1992-1994 to verify pension fund contributions. Steven Scott moved for summary judgment, asserting that fifteen prior settlement agreements with William Moriarity, a Pension Fund Trustee and Local 802 President, fully settled all monetary claims. The court found that Steven Scott reasonably relied on Moriarity's apparent authority, and the Pension Fund's actions, including cashing checks and failing to repudiate the agreements, established equitable estoppel and ratification. Consequently, the court granted Steven Scott's motion for summary judgment, concluding that the Pension Fund was bound by the agreements and dismissing the plaintiffs' complaint.

ERISALMRAPension FundEquitable EstoppelApparent AuthorityRatificationSettlement AgreementsSummary JudgmentEmployer ContributionsUnion
References
21
Case No. MISSING
Regular Panel Decision

Symetra Life Insurance v. Rapid Settlements, Ltd.

This case involves the National Association of Settlement Purchasers (NASP) seeking a permanent injunction against Rapid Settlements, Ltd., a factoring company. NASP alleged that Rapid Settlements improperly uses arbitration and enforces rights of first refusal and security interests in structured settlement payment rights without state-court approval, thereby circumventing state Structured Settlement Protection Acts (SSPAs). The court found that Rapid Settlements' practices illegally circumvent the SSPAs, cloud title to annuitants' payment rights, raise transaction costs for NASP members, and place them at a competitive disadvantage. The court rejected Rapid Settlements' defenses, including preemption by the Federal Arbitration Act and an 'unclean hands' argument against NASP. The court granted NASP's application, permanently enjoining Rapid Settlements from using arbitration or enforcing unapproved rights of first refusal and security interests to effectuate transfers of structured settlement payment rights.

Structured SettlementsFactoring CompaniesAnnuity PaymentsArbitrationInjunctionState LawFederal LawStructured Settlement Protection ActsRights of First RefusalSecurity Interests
References
33
Case No. MISSING
Regular Panel Decision

Texas Workers' Compensation Insurance Fund v. Texas Employment Commission

Imelda Martinez, a former Vice President of Fraud Investigations for the Texas Workers’ Compensation Insurance Fund (Fund), was terminated and offered a three-month severance package. The termination memorandum conditioned the severance only on returning company equipment and documents. However, she was verbally informed that the severance was also contingent on signing a "Full and Complete Settlement and Release Agreement." Martinez complied with the written condition but did not sign the release. The Fund subsequently refused to pay severance, leading Martinez to file a wage claim with the Texas Employment Commission (TEC) under the Texas Payday Law. The TEC ruled in favor of Martinez, stating that the oral condition was unenforceable as it contradicted the written agreement. The Fund then sought judicial review in the District Court in Kleberg County, which granted summary judgment to the TEC. The appellate court affirmed the trial court's decision, concluding that the oral condition precedent was inconsistent with the written agreement and therefore invalid, upholding Martinez's entitlement to severance pay.

Severance PayEmployment LawWage DisputeTexas Payday LawContract InterpretationCondition PrecedentSummary JudgmentAppellate ReviewSubstantial EvidenceWritten Agreement
References
9
Case No. 03-01-00631-CV
Regular Panel Decision
Jun 21, 2002

Everest National Insurance Company v. Texas Workers' Compensation Commission Subsequent Injury Fund Leonard W. Riley, Jr., in His Official Capacity as Director of Texas Workers' Compensation Commission And John Casseb, in His Official Capacity as Administrator of Subsequent Injury Fund

Everest National Insurance Company (Everest) sought reimbursement from the Subsequent Injury Fund for overpaid workers' compensation benefits after district court judgments reversed prior agency decisions. The Fund denied a portion of the requested amount, leading Everest to file a declaratory judgment suit in district court. The district court dismissed the suit, citing lack of subject-matter jurisdiction due to Everest's alleged failure to exhaust administrative remedies. The Texas Court of Appeals reversed this decision, holding that Everest was not required to exhaust administrative remedies because the Fund had previously stated no such remedies existed. The appellate court found Everest was authorized to bring a direct suit for declaratory relief under the Uniform Declaratory Judgments Act to enforce the Fund's statutory obligation, remanding the case for a decision on the merits.

Workers' CompensationInsurance ReimbursementSubsequent Injury FundAdministrative Procedure ActDeclaratory JudgmentExhaustion of Administrative RemediesSubject-Matter JurisdictionStatutory InterpretationTexas Court of AppealsJudicial Review
References
8
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