Huit v. Ashwater Burns

[ADMINISTRATIVE LAW]

In Huit v. Ashwater Burns, Inc.,[1] the supreme court held when a superior court remands a case to an administrative agency decisions are not final if they contemplate further proceedings,[2] and the Alaska’s worker compensation statute requires employers to provide substantial evidence an employees’ injuries are not work-related to rebut the presumption the employee’s injury is compensable.[3] Joseph Huit, an employee of Ashwater Burns, was scratched while working.[4] Subsequently, Huit developed a medical condition warranting hospitalization.[5] After hospitalization, Huit received conflicting medical opinions as to whether the endocarditis resulted from the scratch.[6] The Alaska’s Worker’s Compensation Board found that Huit’s injury was presumed compensable because Ashwater identified no alternate cause to rebut medical professionals concessions that Huit’s scratch could have caused his infection.[7] Ashwater then appealed to Alaska’s Worker’s Compensation Commission, which decided the Board erred in requiring substantial evidence of alternate causes, as opposed to evidence employment did not substantially cause the injury.[8] Overruling the Commission, the supreme court determined decisions are not final while litigants can still submit evidence that may alter the decision.[9] While the court considered that the Commission was created for the purpose of expediency, it declared that litigants could appeal decisions that raise important issues of law.[10] After justifying granting the appeal, the court reversed the Commission’s finding that Ashwater had rebutted the presumption that Huit’s injury was compensable.[11] The court determined that Ashwater was required to prove Huit’s employment did not give rise to his infection, either by showing the scratch was not a possible cause of injury or by identifying another possible cause.[12] Reversing the Commission, the supreme court held administrative agency decisions are not final if they contemplate further proceedings,[13] and employers must provide substantial evidence that employees’ injuries are not work related in order to rebut the presumption that employees’ injuries are compensable under Alaska’s worker compensation statute.[14]

[1] 372 P.3d 904 (Alaska 2016).
[2] Id. at 914–16.
[3] Id. at 919.
[4] Id. at 908.
[5] Id. at 908–09.
[6] Id. at 909–10.
[7] Id. at 910–11.
[8] Id. at 911–12.
[9] Id. at 914.
[10] Id. at 916.
[11] Id.
[12] Id. at 919–20.
[13] Id. at 914–916.
[14] Id. at 919.

Huit v. Ashwater Burns

[ADMINISTRATIVE LAW]

In Huit v. Ashwater Burns, Inc.,[1] the supreme court held when a superior court remands a case to an administrative agency decisions are not final if they contemplate further proceedings,[2] and the Alaska’s worker compensation statute requires employers to provide substantial evidence an employees’ injuries are not work-related to rebut the presumption the employee’s injury is compensable.[3] Joseph Huit, an employee of Ashwater Burns, was scratched while working.[4] Subsequently, Huit developed a medical condition warranting hospitalization.[5] After hospitalization, Huit received conflicting medical opinions as to whether the endocarditis resulted from the scratch.[6] The Alaska’s Worker’s Compensation Board found that Huit’s injury was presumed compensable because Ashwater identified no alternate cause to rebut medical professionals concessions that Huit’s scratch could have caused his infection.[7] Ashwater then appealed to Alaska’s Worker’s Compensation Commission, which decided the Board erred in requiring substantial evidence of alternate causes, as opposed to evidence employment did not substantially cause the injury.[8] Overruling the Commission, the supreme court determined decisions are not final while litigants can still submit evidence that may alter the decision.[9] While the court considered that the Commission was created for the purpose of expediency, it declared that litigants could appeal decisions that raise important issues of law.[10] After justifying granting the appeal, the court reversed the Commission’s finding that Ashwater had rebutted the presumption that Huit’s injury was compensable.[11] The court determined that Ashwater was required to prove Huit’s employment did not give rise to his infection, either by showing the scratch was not a possible cause of injury or by identifying another possible cause.[12] Reversing the Commission, the supreme court held administrative agency decisions are not final if they contemplate further proceedings,[13] and employers must provide substantial evidence that employees’ injuries are not work related in order to rebut the presumption that employees’ injuries are compensable under Alaska’s worker compensation statute.[14]

[1] 372 P.3d 904 (Alaska 2016).
[2] Id. at 914–16.
[3] Id. at 919.
[4] Id. at 908.
[5] Id. at 908–09.
[6] Id. at 909–10.
[7] Id. at 910–11.
[8] Id. at 911–12.
[9] Id. at 914.
[10] Id. at 916.
[11] Id.
[12] Id. at 919–20.
[13] Id. at 914–916.
[14] Id. at 919.