Morgan, Jr., Otto v. Lockheed Martin Corporation
In an interlocutory appeal, the employer appealed the denial of its motion for summary judgment based on the statute of limitations. The employee's surviving spouse filed a petition for death benefits, asserting that the employee's death was caused by employment-related diseases. The employer contended that the claim was time-barred as the statute of limitations had expired one year after the employee received federal benefits for his occupational illness. The trial court denied the motion, finding disputed issues of material fact regarding when the employee became incapacitated from working. The Workers' Compensation Appeals Board affirmed the trial court's decision, emphasizing that an impairment rating or receipt of federal benefits does not conclusively establish incapacity for work, which is crucial for triggering the statute of limitations. The Board remanded the case for further proceedings.