Vandenberg v. State, Department of Health & Social Services

[ADMINISTRATIVE LAW]

In Vandenberg v. State, Department of Health & Social Services,[1] the supreme court held that administrators erred in applying only one job description to a reemployment benefit claim where the applicant’s actual job was more physically strenuous than that job’s description provided.[2] After sustaining a work-related injury, Vandenberg applied for reemployment benefits.[3] In compiling the reemployment benefit claim, the independent rehabilitiation specialist assigned to the case determined that no single job description accurately characterized Vandenberg’s position and advocated for listing two descriptions instead, a medium strength and a more sedentary job.[4] Relying on case law, the Alaska Workers’ Compensation Board, however, disagreed, deciding only the sedentary job described the demands of Vandenberg’s position, thereby making her ineligible for benefits.[5] The supreme court, however, sided with Vandenberg, reasoning that the administrators read the law too narrowly.[6] Rather, the court held that the state could be permitted to select multiple job descriptions if warranted by consideration of the tasks and duties of the applicant’s job.[7] Upon such consideration of the tasks and duties of Vandenberg’s job, the court agreed that her job was significantly different from the one selected by the administrators.[8] Reversing and remanding the administrators’ decisions, the supreme court held that two job descriptions could be used to describe an applicant’s job if just one cannot properly describe the job’s tasks and duties.[9]

[1] 371 P.3d 602 (Alaska 2016).

[2] See id. at 603-04.

[3] Id. at 603.

[4] Id. at 604.

[5] Id. at 603.

[6] Id. at 608.

[7] Id.

[8] See id. at 608-09.

[9] See id.

Vandenberg v. State, Department of Health & Social Services

[ADMINISTRATIVE LAW]

In Vandenberg v. State, Department of Health & Social Services,[1] the supreme court held that administrators erred in applying only one job description to a reemployment benefit claim where the applicant’s actual job was more physically strenuous than that job’s description provided.[2] After sustaining a work-related injury, Vandenberg applied for reemployment benefits.[3] In compiling the reemployment benefit claim, the independent rehabilitiation specialist assigned to the case determined that no single job description accurately characterized Vandenberg’s position and advocated for listing two descriptions instead, a medium strength and a more sedentary job.[4] Relying on case law, the Alaska Workers’ Compensation Board, however, disagreed, deciding only the sedentary job described the demands of Vandenberg’s position, thereby making her ineligible for benefits.[5] The supreme court, however, sided with Vandenberg, reasoning that the administrators read the law too narrowly.[6] Rather, the court held that the state could be permitted to select multiple job descriptions if warranted by consideration of the tasks and duties of the applicant’s job.[7] Upon such consideration of the tasks and duties of Vandenberg’s job, the court agreed that her job was significantly different from the one selected by the administrators.[8] Reversing and remanding the administrators’ decisions, the supreme court held that two job descriptions could be used to describe an applicant’s job if just one cannot properly describe the job’s tasks and duties.[9]

[1] 371 P.3d 602 (Alaska 2016).

[2] See id. at 603-04.

[3] Id. at 603.

[4] Id. at 604.

[5] Id. at 603.

[6] Id. at 608.

[7] Id.

[8] See id. at 608-09.

[9] See id.