Ryan v. Potlatch Corp.

Respondent suffered a work-related back injury. Respondent and her employer entered into a “full, final, and complete” settlement of Respondent’s claims for workers’ compensation benefits related to that injury. Respondent later filed a claim petition seeking additional benefits for the back injury, alleging a lumbar spine injury with consequential depression and anxiety. The employer moved to dismiss the petition on the ground that Respondent was first required to bring a motion to vacate the existing settlement agreement before bringing a new claim. The workers’ compensation judge denied the motion, concluding that the settlement agreement did not foreclose a later claim for consequential psychological injury. The Workers’ Compensation Court of Appeals affirmed, concluding that the settlement agreement did not foreclose claims from the same incident that were not mentioned in the agreement without evidence that those claims were contemplated by the parties at the time they entered into the agreement. The Supreme Court reversed, holding that the language of the settlement agreement was sufficient settle conditions and complications that arise out of, and are a consequence of, Respondent’s workers’ compensation injury. View "Ryan v. Potlatch Corp." on Justia Law