Newsletters
Risk Central
Digital EditionOklahoma Supreme Court: Workers’ Comp Claims Require Continuous Activity
The Oklahoma Supreme Court has provided a significant clarification on the dismissal of inactive workers’ compensation claims, offering a key victory for employers and insurers.
In a recent decision, OBI Holding Company vs. Schultz-Butzbach, the court ruled that a claim must be dismissed if the employee fails to seek or receive benefits for any six-month period, establishing an ongoing duty for claimants to actively pursue their cases. This ruling provides a clearer path for closing long-dormant files, helping to manage claim reserves and reduce long-tail liability for insurers.
The case originated from a knee injury claim filed by employee Shaneese Schultz-Butzbach against OBI Holding Company. The employer and its insurer, Sentry Casualty Company, denied the claim was work-related. An independent medical examiner agreed, opining that the injury stemmed from a preexisting condition.
Following this examination, the case saw no activity for nine months; the employee did not seek further medical treatment or file any additional pleadings. Citing this period of inactivity, the employer moved to have the claim dismissed.
At the heart of the dispute were differing interpretations of an Oklahoma statute governing claim dismissals. The employer and insurer argued that the law requires a claimant to continuously pursue their case. They contended that any six-month period in which an employee does not “receive or seek benefits, including medical treatment” is grounds for dismissal.
In response, the employee argued that she had already satisfied the law’s requirements by requesting a hearing within the first six months of filing her claim. She asserted this initial action was sufficient to prevent dismissal indefinitely and also challenged the constitutionality of the statute itself.
In its analysis, the Oklahoma Supreme Court sided with the employer, reversing the decisions of the Administrative Law Judge and the Workers’ Compensation Commission. The court explained that the statute contains two distinct and independent conditions.
The first requires a claimant to request a hearing within six months of filing if a dispute exists. The second imposes an ongoing obligation on the claimant to remain active in their case. The court stated that allowing an initial action to protect a claim from dismissal forever “would be contrary to the statute’s clear purpose of preventing stale or inactive claims.”
The court also dismissed the employee’s constitutional challenges, finding the law applies equally to all claimants and serves the state’s legitimate interest in the efficient resolution of claims.
Ultimately, the Oklahoma Supreme Court vacated the lower commission’s order and granted the employer’s motion to dismiss the claim.
View the full opinion here. &
