TOPIC 8.10

Topic  8.10.1  Section 8(i) Settlements—Generally

Announcemnt—Settlement Judge Notice

            OALJ continues to experience a high success rate (75 percent) of cases settling through the Settlement Judge process in Longshore cases.  Requests for Settlement Judge Appointments in Longshore cases should be addressed to the Associate Chief Judge for Longshore or to the appropriate district Chief Judge.  While reasonable efforts will be made to accommodate requests for specific dates, there can be no guarantee that requests for specific judges will be granted.

Topic  8.10.1  Section 8(i) Settlements—Generally

Announcement--Proposed Amendment to Medicare Secondary Payer Act

            Two sections of the American Bar Association—Tort Trial and Insurance Practice Section and Section of State and Local Government Law--have issued a report to the ABA’s House of Delegates recommending that the Medicare Secondary Payer Act  correct problems which exist in the implementation of settlements in Longshore and other workers compensation cases.  The recommendation will be considered by the House of Delegates next month [February 2005] at the ABA’s Mid-Winter Meeting

Topic  8.10.1  Section 8(i) Settlements—Generally

[ED. NOTE: The following case is included for informational value only.]

Petition of RJF International Corp. for Exoneration from or Limitation of Liability, Civil and Maritime, (Unpublished)(C.A. No. 01-588S)(D.C. R.I. Aug. 2004).

            A yacht liability insurance policy is the primary payer for medical bills for a seaman. Under the Medicare secondary payer provisions of the Omnibus Budget Reconciliation Act of 1980, the responsibility of the seaman's "maintenance and cure" can not be shifted to Medicare. Cf. Moran Towing & Transp. Co. v. Lombas, 58 F.3d 24 (2d Cir. 1995)(Held, injured seaman's eligibility for free medical treatment under Medicare satisfies a vessel owner's obligation to furnish cure.).

Topic  8.10.1  Section 8(i) Settlements—Generally

Keys v. Ceres Gulf, Inc., (Unpublished)(BRB No. 03-0745) (Jan. 30, 2004).

            While this matter was on appeal, the employer moved for a partial remand, noting that it had reached an 8(i) settlement but also requesting that it be allowed to pursue its appeal regarding Section 8(f).  The Director asserted that employer’s signed settlement with the claimant precluded the employer from obtaining Section 8(f) relief and required dismissal of the appeal.  Agreeing with the director, the Board noted that there is no procedural mechanism for bifurcating an appeal.

            The Board, denying the employer’s motion for partial remand, remanded the full case for consideration of the settlement agreement.  The Board stated:

If the settlement is approved and establishes compensation due for any period for which the Special Fund could be liable if Section 8(f) relief were granted, then employer’s continuation of its appeal is precluded by Section 8(i)(4).  If, however, the approved settlement affects only employer’s liability, i.e., the Fund cannot be liable for reimbursement to employer of any sums due under the settlement, then employer may seek reinstatement of its appeal.  In this event, or in the event that the proposed settlement is not approved, employer may request reinstatement by filing notice with the Board…

Topic  8.10.1  Section 8(i) Settlements--Generally

Jeschke v. Jones Stevedoring Co., 36 BRBS 35 (2002).

            Here the claimant was prescribed binaural analog hearing aids, and began wearing completely-in-the-canal hearing aids to reduce wind noise. Subsequently he filed a hearing-loss claim against two employers and entered into a Section 8(i) settlement with one who accepted responsibility and agreed to be responsible for all future medical expenses. Sometime after, the district director issued a compensation order approving the settlement which she stated effected a final disposition of the claim. After that, the claimant obtained state-of-the-art digital hearing aids. The Board found that the ALJ was within reason in finding that the responsible employer who had settled this claim was liable for the new hearing aids as the settlement had indicated it would remain liable for all future reasonable and necessary medical expenses for treatment of the claimant's work-related hearing loss. The ALJ had determined that this was a work-related hearing loss and that this employer had accepted liability in the settlement agreement as the responsible party under the LHWCA.

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Topic  8.10.2  Section 8(i) Settlements—Persons Authorized

Mobley v. MONTCO, Inc., (Unpubished), 2004 WL 307478 (E.D. La. February 17, 2004).

            Here the federal district court judge held that the court had the power to force the plaintiff in a Jones Act case to sign a “Receipt and Release” even though the settlement agreement was not reduced to writing.

[ED. NOTE:  The reader may want to keep in mind that the settlement of a related non-longshore action will not bar a later claim brought under the LHWCA, unless the settlement meets the requirements of Section 8(i).  Ryan v. Alaska Constructors, 24 BRBS 65 (1990) (Claimant’s claim under LHWCA was not barred by a previous settlement of a Jones Act claim entered into with his employer, involving the same injury); see also Harms v. Stevedoring Servs. Of America, 25 BRBS 375 (1992).]

Topic  8.10.2  Section 8(i) Settlements--Persons Authorized

O'Neil v. Bunge Corp., 365 F.3d 820 (9th Cir. 2004). [See next entry.]

            The Ninth Circuit held that when a claimant enters into an "agreement" with his employer to settle a case, but passes away prior to signing the settlement agreement, there is no enforceable Section 8(i) settlement agreement. The Ninth Circuit found that the Section 8(i) implementing regulations, 20 C.F.R. §§ 702.241 to 702.243, are clear on their face: a settlement is contingent upon the submission of a signed settlement application.

Topic  8.10.2  Section 8(i) Settlements--Persons Authorized

O'Neil v. Bunge Corp., 36 BRBS 25 (2002).  [See Above.]

            For this matter geographically within the Ninth Circuit (but without pertinent Ninth Circuit case law), the Board relied on Henry v. Coordinated Caribbean Transport, 204 F.3d 609, 34 BRBS 15 (CRT) (5th Cir. 2000), aff'g 32 BRBS 29 (1998). To hold that where a decedent dies without having signed a proposed settlement agreement, and the agreement had not been submitted for administrative approval prior to death, it is not an enforceable settlement agreement under Section 8(i).

            Additionally, the Board noted that the ALJ had not erred in refusing to enforce the proposed agreement under common law contract principles since Section 8(i) provides the only basis for settlement of claims under the LHWCA and Sections 15(b) and 16 of the LHWCA prohibit the settlement of claims except in accordance with Section 8(i) and its implementing regulations.

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Topic  8.10.3  Section 8(i) Settlements—Structure of Settlement

O'Neil v. Bunge Corp., 365 F.3d 820 (9th Cir. 2004). [See next entry.]

            The Ninth Circuit held that when a claimant enters into an "agreement" with his employer to settle a case, but passes away prior to signing the settlement agreement, there is no enforceable Section 8(i) settlement agreement. The Ninth Circuit found that the Section 8(i) implementing regulations, 20 C.F.R. §§ 702.241 to 702.243, are clear on their face: a settlement is contingent upon the submission of a signed settlement application.

Topic  8.10.3  Section 8(i) Settlements--Structure of Settlement; Withdrawal of                                    Claim/Settlement Agreement

O'Neil v. Bunge Corp., 36 BRBS 25 (2002).  [See Above.]

            For this matter geographically within the Ninth Circuit (but without pertinent Ninth Circuit case law), the Board relied on Henry v. Coordinated Caribbean Transport, 204 F.3d 609, 34 BRBS 15 (CRT) (5th Cir. 2000), aff'g 32 BRBS 29 (1998). To hold that where a decedent dies without having signed a proposed settlement agreement, and the agreement had not been submitted for administrative approval prior to death, it is not an enforceable settlement agreement under Section 8(i).

            Additionally, the Board noted that the ALJ had not erred in refusing to enforce the proposed agreement under common law contract principles since Section 8(i) provides the only basis for settlement of claims under the LHWCA and Sections 15(b) and 16 of the LHWCA prohibit the settlement of claims except in accordance with Section 8(i) and its implementing regulations.

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Topic  8.10.4   Section 8(i) Settlements--Time Frame

Jenkins v. Puerto Rico Marine, Inc., 36 BRBS 1(2002).

            Here the claimant argues that the district director erred in denying his request for penalties and interest on Section 8(i) settlement proceeds. When the district director received the parties' application for settlement, the case was on appeal before the Eleventh Circuit and thus the district director did not have jurisdiction. He therefore concluded that the 30-day time limit for automatic approval of the settlement was tolled and instructed the parties to request remand of the case so that he could fully consider the agreement. The crux of the claimant's contention is that, contrary to the district director's findings, the 30 day time limit for consideration of the settlement could not be tolled and, therefore, the settlement was "automatically" approved and as a result, the employer was liable for interest and penalties which accrued from the date of the 30th day until payment to the claimant of the agreed upon amounts.

            Citing Section 702.241(b), 20 C.F.R.. §§ 702.241(d) ("... The thirty day period as described in paragraph (f) of this section begins when the remanded case is received by the adjudicator."), the Board held that the 30-day period had properly been tolled. The Board further noted that the 30-day period would have been tolled in any event since the parties had not provided a complete application as needed to comply with Section 702.242 of the regulations.

            Claimant also alleged that in approving the settlement, the district director in effect nullified the Board's prior attorney fee award and that award should be considered separate and apart from the attorney's fee agreed upon in the parties' settlement agreement. However, based on the wording in the settlement agreement, the Board found that the district director rationally construed the settlement agreement as conclusively deciding the issue of all attorney's fees due in this case.

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Topic  8.10.6  Section 8(i) Settlements--Withdrawal of Claim/Settlement Agreement

Keys v. Ceres Gulf, Inc., (Unpublished)(BRB No. 03-0745) (Jan. 30, 2004).

            While this matter was on appeal, the employer moved for a partial remand, noting that it had reached an 8(i) settlement but also requesting that it be allowed to pursue its appeal regarding Section 8(f).  The Director asserted that employer’s signed settlement with the claimant precluded the employer from obtaining Section 8(f) relief and required dismissal of the appeal.  Agreeing with the director, the Board noted that there is no procedural mechanism for bi-furcating an appeal.

            The Board, denying the employer’s motion for partial remand, remanded the full case for consideration of the settlement agreement.  The Board stated:

If the settlement is approved and establishes compensation due for any period for which the Special Fund could be liable if Section 8(f) relief were granted, then employer’s continuation of its appeal is precluded by Section 8(i)(4).  If, however, the approved settlement affects only employer’s liability, i.e., the Fund cannot be liable for reimbursement to employer of any sums due under the settlement, then employer may seek reinstatement of its appeal.  In this event, or in the event that the proposed settlement is not approved, employer may request reinstatement by filing notice with the Board…

Topic  8.10.6  Section 8(i) Settlements–Withdrawal of Claim/Settlement Agreement

Thomas v. Raytheon Range Systems, (Unpublished) (BRB No. 01-0891) (August 13, 2002).

            The claimant herein, without aide of counsel, now challenges a Section 8(i) settlement on the grounds that: (1) she signed the agreement because she would otherwise have to wait to have her claim adjudicated and (2) she did not know that by signing the agreement she would not get to testify about her post injury employment and termination. In upholding the settlement, the Board stated that waiting for a hearing is not duress and reflects no more than a choice faced by any claimant in deciding whether to proceed with, or settle, a pending case. "Moreover, the fact that claimant did not get to testify before the [ALJ] concerning her post-injury employment and termination does not establish grounds for negating or modifying the settlement."

Topic  8.10.6  Section 8(i) Settlements--Withdrawal of Claim/Settlement Agreement

Hansen v. Matson Terminals, Inc., 37 BRBS 40 (2003).

            This is the “Appeal of the Order Approving Settlement and the Order Denying Motion to Reconsider Approval of Settlement.”   Prior to the submission of the settlement agreement to the claimant and his counsel, the employer received a “rumor” that the claimant was being considered for longshore employment.  The employer subsequently contacted the claimant’s counsel who, after consulting with the claimant, informed the employer that the claimant might return to longshore employment upon a release from his physician. ( The claimant did return to longshore employment on March 25, 2002 as a wharf gang member.)  The settlement agreement was thereafter faxed to the claimant’s counsel, was signed and returned to employer.  The employer’s Human Resources Department was unable to verify the claimant’s employment status.  Subsequently, the employer’s two carriers executed the settlement agreement and forwarded it along with the appropriate attachments to the ALJ who issued an Order approving the executed settlement agreement on April 23, 2002.

            Later the employer asserted that it became aware, on April 25, 2002, of the claimant’s re-employment and on April 26, 2002, filed a “Motion to Disapprove Settlement Agreement and/or to Reconsider Approval of Settlement.”  The ALJ denied relief.  On appeal, the employer challenged the ALJ’s approval of the parties’ executed settlement agreement, asserting that the settlement should be set aside as the claimant returned to longshore employment in violation of a term of the agreement.

            However, as the Board pointed out, the parties’ settlement agreement addresses only the remedy available to the employer should the claimant “return to work as a laborer in the longshore industry after the settlement is approved,” and the remedy it provides is not rescission of the agreement but a credit to be applied to any future claim for benefits.  The Board noted that “Contrary to employer’s position on appeal, the presence of an express right of rescission in a settlement agreement is required in order for employer to protect its interest should a specific contingency arise....The settlement agreement in this case, however, does not specifically provide employer with a right of rescission should some specific event occur prior to approval by the [ALJ].”  Citing Oceanic Butler, Inc. v. Nordahl, 842 F.2d 773, 21 BRBS 33(CRT) (5th Cir. 1988), aff’g 20 BRBS 18 (1987).  The Board further stated, “Accordingly, as the executed settlement agreement sets forth no express right of rescission for employer and contains no express provision allowing employer to escape from its agreement to pay if claimant were to return to work, we reject employer’s contention that the [ALJ] erred in not setting aside the agreement.”  However, the reader is cautioned that this last statement by the Board may be somewhat misleading.  Nordahl, which the Board repeatedly cited as authority in this area of the law, specifically addressed an employer’s ability to include a provision allowing its escape from an agreement during the pre-approval period, not post approval.  The Board even notes this distinction in its footnote 6.  There is no case law which holds that the parties can contract to rescind a settlement agreement if an event occurs after the settlement has become effective.

            Employer also argued that the claimant’s return to work was a material breach of the agreement since he represented that he could not return to work as a laborer.  However, the Board noted that the agreement provided additional reasons for settlement.  Furthermore, the Board noted that the claimant returned to work as a member of a wharf gang, not as a laborer and the employer knew of the claimant’s intention to return to work prior to its execution of the agreement.  “Finally, employer’s argument that claimant’s return to work denied it the benefit of the bargain is misplaced since, as noted by the Fifth Circuit in Nordahl, settlements are essentially a gamble: claimants gamble, inter alia, that the injury will not be as debilitating as the carrier expects, while the carrier gambles, inter alia, that claimant will have less earning capacity on the open labor market than they expect or that claimant has applied an overly optimistic discount rate in evaluating his future rights.” 

Topic  8.10.6  Section 8(i) Settlements--Withdrawal of Claim/Settlement Agreement

Rogers v. Hawaii Stevedores, Inc., 37 BRBS 33 (2003).      

            In an issue of first impression, the Board held that a claimant may withdraw from a settlement agreement prior to its approval.  Citing Oceanic Butler, Inc., v. Nordahl, 842 F.2d 773, 21 BRBS 33 (CRT) (5th Cir. 1988), the Board noted that while the LHWCA and the regulations do not explicitly state that the claimant may rescind a settlement agreement prior to its approval, the reasoning of the Fifth Circuit in Nordahl that a claimant has such a right is compelling.  “The holding that a claimant’s agreement to waive his compensation is not binding upon him unless it is administratively approved, either through the settlement process or pursuant to a withdrawal under Section 702.225, is supported by the structure of the Act.  Consistent with Sections 15(b) and 16, no agreement by a claimant to waive or compromise his right to compensation is valid until it is administratively approved pursuant to Section 8(i).  Thus, claimant may withdraw his agreement at any time prior to approval of the agreement by the [ALJ].”

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Topic  8.10.7  Section 8(i) Settlements--Attorney Fees

Jenkins v. Puerto Rico Marine, Inc.,  36 BRBS 1(2002).

            Here the claimant argues that the district director erred in denying his request for penalties and interest on Section 8(i) settlement proceeds. When the district director received the parties' application for settlement, the case was on appeal before the Eleventh Circuit and thus the district director did not have jurisdiction. He therefore concluded that the 30-day time limit for automatic approval of the settlement was tolled and instructed the parties to request remand of the case so that he could fully consider the agreement. The crux of the claimant's contention is that, contrary to the district director's findings, the 30 day time limit for consideration of the settlement could not be tolled and, therefore, the settlement was "automatically" approved and as a result, the employer was liable for interest and penalties which accrued from the date of the 30th day until payment to the claimant of the agreed upon amounts.

            Citing Section 702.241(b), 20 C.F.R.. §§ 702.241(d) ("... The thirty day period as described in paragraph (f) of this section begins when the remanded case is received by the adjudicator."), the Board held that the 30-day period had properly been tolled. The Board further noted that the 30-day period would have been tolled in any event since the parties had not provided a complete application as needed to comply with Section 702.242 of the regulations.

            Claimant also alleged that in approving the settlement, the district director in effect nullified the Board's prior attorney fee award and that award should be considered separate and apart from the attorney's fee agreed upon in the parties' settlement agreement. However, based on the wording in the settlement agreement, the Board found that the district director rationally construed the settlement agreement as conclusively deciding the issue of all attorney's fees due in this case.

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Topic  8.10.8  Section 8(i) Settlements—Finality of Settlement

Schultz v. United States Marine Corps/MWR, (Unpublished)(BRB No. 03-0473)(March 17, 2004).

            A motion to correct clerical errors in a settlement order, such as where an ALJ merely recited the wrong monetary figures to which the parties had agreed, does not toll the time for filling a notice of appeal of the underlying compensation order.

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Topic  8.10.8.2           Section 8(i) Settlements–Setting Aside Settlements

Thomas v. Raytheon Range Systems, (Unpublished) (BRB No. 01-0891) (August 13, 2002).

            The claimant herein, without aide of counsel, now challenges a Section 8(i) settlement on the grounds that: (1) she signed the agreement because she would otherwise have to wait to have her claim adjudicated and (2) she did not know that by signing the agreement she would not get to testify about her post injury employment and termination. In upholding the settlement, the Board stated that waiting for a hearing is not duress and reflects no more than a choice faced by any claimant in deciding whether to proceed with, or settle, a pending case. "Moreover, the fact that claimant did not get to testify before the [ALJ] concerning her post-injury employment and termination does not establish grounds for negating or modifying the settlement."

Topic  8.10.8.2           Section 8(i) Settlements--Setting Aside Settlements

Hansen v. Matson Terminals, Inc., 37 BRBS 40 (2003).

            This is the “Appeal of the Order Approving Settlement and the Order Denying Motion to Reconsider Approval of Settlement.”   Prior to the submission of the settlement agreement to the claimant and his counsel, the employer received a “rumor” that the claimant was being considered for longshore employment.  The employer subsequently contacted the claimant’s counsel who, after consulting with the claimant, informed the employer that the claimant might return to longshore employment upon a release from his physician. (The claimant did return to longshore employment on March 25, 2002 as a wharf gang member.)  The settlement agreement was thereafter faxed to the claimant’s counsel, was signed and returned to employer.  The employer’s Human Resources Department was unable to verify the claimant’s employment status.  Subsequently, the employer’s two carriers executed the settlement agreement and forwarded it along with the appropriate attachments to the ALJ who issued an Order approving the executed settlement agreement on April 23, 2002.

            Later the employer asserted that it became aware, on April 25, 2002, of the claimant’s re-employment and on April 26, 2002, filed a “Motion to Disapprove Settlement Agreement and/or to Reconsider Approval of Settlement.”  The ALJ denied relief.  On appeal, the employer challenged the ALJ’s approval of the parties’ executed settlement agreement, asserting that the settlement should be set aside as the claimant returned to longshore employment in violation of a term of the agreement.

            However, as the Board pointed out, the parties’ settlement agreement addresses only the remedy available to the employer should the claimant “return to work as a laborer in the longshore industry after the settlement is approved,” and the remedy it provides is not rescission of the agreement but a credit to be applied to any future claim for benefits.  The Board noted that “Contrary to employer’s position on appeal, the presence of an express right of rescission in a settlement agreement is required in order for employer to protect its interest should a specific contingency arise....The settlement agreement in this case, however, does not specifically provide employer with a right of rescission should some specific event occur prior to approval by the [ALJ].”  Citing Oceanic Butler, Inc. v. Nordahl, 842 F.2d 773, 21 BRBS 33(CRT) (5th Cir. 1988), aff’g 20 BRBS 18 (1987).  The Board further stated, “Accordingly, as the executed settlement agreement sets forth no express right of rescission for employer and contains no express provision allowing employer to escape from its agreement to pay if claimant were to return to work, we reject employer’s contention that the [ALJ] erred in not setting aside the agreement.”  However, the reader is cautioned that this last statement by the Board may be somewhat misleading.  Nordahl, which the Board repeatedly cited as authority in this area of the law, specifically addressed an employer’s ability to include a provision allowing its escape from an agreement during the pre-approval period, not post approval.  The Board even notes this distinction in its footnote 6.  There is no case law which holds that the parties can contract to rescind  a settlement agreement if an event occurs after the settlement has become effective.

            Employer also argued that the claimant’s return to work was a material breach of the agreement since he represented that he could not return to work as a laborer.  However, the Board noted that the agreement provided additional reasons for settlement.  Furthermore, the Board noted that the claimant returned to work as a member of a wharf gang, not as a laborer and the employer knew of the claimant’s intention to return to work prior to its execution of the agreement.  “Finally, employer’s argument that claimant’s return to work denied it the benefit of the bargain is misplaced since, as noted by the Fifth Circuit in Nordahl, settlements are essentially a gamble: claimants gamble, inter alia, that the injury will not be as debilitating as the carrier expects, while the carrier gambles, inter alia, that claimant will have less earning capacity on the open labor market than they expect or that claimant has applied an overly optimistic discount rate in evaluating his future rights.” 

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Topic  8.10.9  Section 8(i) Settlements--Section 8(f) Relief

Keys v. Ceres Gulf, Inc., (Unpublished)(BRB No. 03-0745) (Jan. 30, 2004).

            While this matter was on appeal, the employer moved for a partial remand, noting that it had reached an 8(i) settlement but also requesting that it be allowed to pursue its appeal regarding Section 8(f).  The Director asserted that employer’s signed settlement with the claimant precluded the employer from obtaining Section 8(f) relief and required dismissal of the appeal.  Agreeing with the director, the Board noted that there is no procedural mechanism for bi-furcating an appeal.

            The Board, denying the employer’s motion for partial remand, remanded the full case for consideration of the settlement agreement.  The Board stated:

If the settlement is approved and establishes compensation due for any period for which the Special Fund could be liable if Section 8(f) relief were granted, then employer’s continuation of its appeal is precluded by Section 8(i)(4).  If, however, the approved settlement affects only employer’s liability, i.e., the Fund cannot be liable for reimbursement to employer of any sums due under the settlement, then employer may seek reinstatement of its appeal.  In this event, or in the event that the proposed settlement is not approved, employer may request reinstatement by filing notice with the Board…

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Topic  8.10.12            Section 8(i) Settlements—Alternative Dispute Resolution

ERRATA

            The OALJ Internet Home Page address should read:  http://www.oalj.dol.gov.

Topic  8.10.12            Section 8(i) Settlements—Alternative Dispute Resolution

Autin v. Nabors Offshore Corp., (Unpublished)(Civ. No. 0203704)(E.D. of La. March 5, 2004), 2004 U.S. Dist. LEXIS 3507.

            Here a worker's status as either a Jones Act seaman or as a maritime worker covered by the LHWCA was at issue. The employer contended that in evaluating seaman status, the court must consider only the plaintiff's work on a fixed platform. In contrast, the plaintiff argued that his career with the employer did not involve a termination and re-hire, but rather a transfer, and thus the status question must be resolved in the context of his entire two-plus years employment at employer, largely in a seaman's capacity.

            The employer filed a Motion to Compel Arbitration and Alternatively, for Summary Judgment. The judge denied both motions noting that the matter was not subject to arbitration:

Plaintiff's claim is either under the Jones Act or the LHWCA. By law, Jones Act claims are not subject to arbitration. Brown v. Nabors Offshore Corp., 339 F.3d 391 (5th Cir. 2003). Moreover, LHWCA claims are specifically excluded from arbitration by the very terms of the [employer's] DRP ("notwithstanding anything to the contrary in this Program, the Program does not apply to claims for workers' compensation benefits.") Accordingly, there is no possible scenario under which plaintiff's claims are subject to arbitration.

[ED. NOTE: Although it has not been litigated as to whether a contractual agreement can specifically exclude a longshore claim from ADR as a public policy, the question is mooted nevertheless since all parties to a claim must request the appointment of a settlement judge at OALJ.]

Summary judgment was denied since there remain outstanding fact issues.

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