Background
Teresa Crutchfield injured her lower back in 2011 while working as a certified nursing assistant for the Carolyn Boone Lewis Health Center. Her employer and its insurer voluntarily paid disability compensation and medical benefits without a formal award. They stopped her wage-loss payments in December 2012 after she declined an offered light-duty position, and the insurer stopped paying medical benefits in March 2015 after an independent medical examination.
Although Crutchfield reportedly challenged the 2012 cutoff through an informal conference and requested a formal hearing, no hearing occurred, and the administrative record did not explain why. She took no further action for several years. In 2022, she sought total-disability compensation dating back to December 2012 and reimbursement of medical expenses incurred after March 2015. An administrative law judge denied the claims as untimely, and the Compensation Review Board affirmed under D.C. Code § 32-1514(a).
The Court’s Holding
The D.C. Court of Appeals affirmed. The majority held that when an employer voluntarily pays compensation without an award and then discontinues those payments, Section 32-1514(a) gives the employee one year from the last payment to file a claim requesting adjudication and resumption of benefits. Crutchfield therefore had one year after the December 2012 termination of wage-loss payments and one year after the March 2015 termination of medical benefits. Her 2022 filing was untimely.
The court rejected Crutchfield’s contention that her timely 2011 claim eliminated the need for another filing. Because the employer was voluntarily paying benefits at that time, the 2011 filing triggered no adjudication and could not have challenged benefit terminations that had not yet occurred. The court also held that Crutchfield waived any argument that her reported 2013 request for a formal hearing satisfied the one-year limitations period because she had not raised that contention before the agency or on appeal.
Judge Howard dissented. He read Section 32-1514(a)’s statement that “no further written claims are necessary” after an initial claim to mean that Crutchfield’s 2011 filing preserved her claim. In his view, her challenge to the termination of benefits remained pending because the requested adjudication never resulted in a final or compensation order.
Key Takeaways
- When benefits are paid voluntarily without an award, a worker generally must file a claim within one year after the last payment to challenge their termination.
- An earlier claim filed while voluntary benefits are being paid does not automatically preserve a later request to reinstate terminated benefits when no adjudication remains pending.
- The court treated the limitations period as applying separately to the 2012 cutoff of wage-loss benefits and the 2015 cutoff of medical benefits.
Why It Matters
The decision imposes a firm deadline on D.C. workers seeking to contest the termination of benefits that were paid voluntarily without a formal award. Even a timely claim filed after the original workplace injury may not preserve a challenge to a later cessation of payments.
The dissent highlights a significant disagreement over whether an initial claim remains alive until the agency enters a final order. For practitioners, the ruling underscores the need to file and actively preserve a request for adjudication within one year after each termination of voluntary benefits.