Texas Mutual Insurance Company v. Bertila Chicas, Individually and as Beneficiary of Santiago Chicas
This case addresses whether the 45-day deadline to seek judicial review of a decision by a Division of Workers’ Compensation appeals panel is jurisdictional. Santiago Chicas sustained fatal injuries in a fall while doing yard work for an employer whose insurer was Texas Mutual Insurance Company. Bertila Chicas, Santiago's wife, sought workers' compensation benefits, leading to administrative proceedings where a hearing officer and subsequently an appeals panel denied her claim. Chicas initially filed a wrongful-death suit in probate court, amending her pleadings to seek judicial review of the administrative decision, but the probate court dismissed her claims due to lack of jurisdiction. She then refiled in district court after the 45-day deadline. The district court granted Texas Mutual's plea to the jurisdiction, ruling the deadline jurisdictional. The court of appeals reversed, holding the deadline mandatory but not jurisdictional. The Supreme Court of Texas affirmed the court of appeals' decision, concluding that the 45-day deadline under Texas Labor Code section 410.252(a) is not jurisdictional, and remanded the case for further proceedings. The Court expressly overruled previous appellate court decisions that held otherwise.