Griggs v. Triple S Industrial Corp.

CHARLES KREGER, Justice,

dissenting.

I respectfully dissent. Section 451.001(4) of the Texas Labor Code provides that “[a] person may not discharge or in any other manner discriminate against an employee because the employee has: (4) testified or is about to testify in a proceeding under Subtitle A.” Tex. Lab. Code Ann. § 451.001(4) (Vernon 2006) (emphasis added). The majority acknowledges a benefit review conference is a proceeding under Subtitle A of the Workers’ Compensation Act.

When a disputed compensation claim arises, a benefit review conference is a mandatory prerequisite before any party to the dispute can proceed with a contested hearing or arbitration. Tex. Lab.Code Ann. § 410.024(a) (Vernon 2006). Because the employer’s insurance carrier denied David Griggs’ claim, he was required to request a benefit review conference before seeking further relief. See id. As the majority correctly notes, a benefit review conference is not a proceeding of record, and although the benefit review officer may not take testimony, he/she “may direct questions to an employee, an employer, or a representative of an insurance carrier to supplement or clarify information in a claim file.” Tex. Lab.Code Ann. § 410.026(c) (Vernon 2006). This appears to be consistent with the purpose of a benefit review conference as set out under section 410.021 of the Labor Code:

A benefit review conference is a nonad-versarial, informal dispute resolution proceeding designed to:

(1) explain, orally and in writing, the rights of the respective parties to a workers’ compensation claim and the procedures necessary to protect those rights;
(2) discuss the facts of the claim, review available information in order to evaluate the claim, and delineate the disputed issues; and
(3) mediate and resolve disputed issues by agreement of the parties in accordance with this subtitle and the policies of the division.

*414Tex. Lab.Code ANN. § 410.021 (Vernon 2006) (emphasis added).

The benefit review conference provisions contained in the Texas Labor Code also refer to portions of the Texas Administrative Code, particularly 28 Tex. Admin. Code §§ 141.1-141.7 (2006) (Tex. Dept, of Ins., Div. of Workers’ Comp., Dispute Resolution-Benefit Review Conference). Section 141.4 is titled, “Filing and Exchanging Pertinent Information,” and provides, in pertinent part, the following:

(a) As used in this section, “.pertinent information” means all information relevant to the resolution of the disputed issue or issues to be addressed at the benefit review conference, including, but not limited to:
(1) information relating to the employee’s wages;
(2) information relating to the employee’s medical condition;
(3) witness statements; and
(4) the names of witnesses who will attend the conference.

Id. § 141.4(a)(1)-(4) (emphasis added).

Section 141.5, titled “Description of the Benefit Review Conference,” includes the following selected provisions:

(a) Definitions. As used in this section, “participant” means an individual entitled or permitted to attend and take part in a benefit review conference. Participants include:
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(4) any other individual, at the discretion of the benefit review officer.

Id. § 141.5(a)(4). Section 141.5 then explains that the benefit review conference consists of three parts: (1) opening, (2) mediation, and (3) closing. During the “mediation” part, the benefit review officer “shall”:

(1)ask and answer questions of the parties and other participants;
(2) encourage the parties to discuss the disputed issues, and ask and answer questions;
(3) permit the employer to present evidence relevant to the disputed issues;
(4) permit other participants to discuss the disputed issues, and ask and answer questions, to the extent the benefit review officer deems appropriate[.]

Id. § 141.5(d)(1)-(4) (emphasis added).

The majority interprets section 451.001 in light of the provisions in section 410.026(c) & (d) and finds the “most compelling interpretation” requires holding that Pamela Griggs did not engage in a protected activity under section 451.001 because she “neither testified nor was about to testify in a proceeding under the workers’ compensation statutes[.]” I agree that the starting point in statutory construction is to construe the provision(s) as written and, if possible, ascertain the Legislature’s intent from the language. See Marcus Cable Assocs., L.P. v. Krohn, 90 S.W.3d 697, 706 (Tex.2002). However, even when a statute is not ambiguous on its face, we may consider other factors to determine the Legislature’s intent, including the object the statute seeks to obtain, legislative history, and the consequences of a particular construction. Id.; see also Helena Chem. Co. v. Wilkins, 47 S.W.3d 486, 493 (Tex.2001) (citing Tex. Gov’t Code Ann. § 311.023 (Vernon 2005)). Moreover, we must consider the statute as a whole and attempt to harmonize its various provisions. Marcus Cable, 90 S.W.3d at 706; Helena Chem., 47 S.W.3d at 493. “We should not give one provision a meaning out of harmony or inconsistent with other provisions, although it might be susceptible to such a construction standing alone. We must presume that the Legislature intends an entire statute to be effective and that a just and reasonable result is *415intended.” Helena Chem., 47 S.W.3d at 493 (citation omitted)(citing Tex. Gov’t Code Ann. § 311.021(2), (3)(Vernon 2005)).

In Texas Mexican Railway Co. v. Bouchet, 963 S.W.2d 52 (Tex.1998), the Texas Supreme Court reaffirmed its previous interpretation of the statutoiy predecessor to section 451.001, Tex.Rev.Civ. Stat. Ann. art. 8307c, as follows:

The Legislature enacted article 8307c in 1971 to protect “persons who file a claim or hire an attorney or aid in filing a claim or testify at hearings concerning a claim under the Texas Workmen’s Compensation Act,” see Act of April 22, 1971, 62d Leg., R.S., ch. 115, 1971 Tex. Gen. Laws 884, because those persons “are alleged to be often fired or discriminated against by employers for such claims.” HOUSE COMM. ON JUDICIARY, BILL ANALYSIS, Tex. H.B. 113, 62d Leg., R.S. (1971); see also Carnation Co. v. Borner, 610 S.W.2d 450, 453 (Tex.1980) (“The Legislature’s purpose in enacting article 8307c was to protect persons who are entitled to benefits under the Worker’s Compensation Law and to prevent them from being discharged by reason of taking steps to collect such benefits.”).
... We need not speculate, however, about the Legislature’s intent. The bill analysis from the House Committee on the Judiciary noted that the purpose of article 8307c was to protect “persons who bring Workmen’s Compensation claims or testify in such actions.”
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... As we have previously recognized, the recodification of article 8307c was not a substantive revision. See [City of LaPorte v.] Barfield, 898 S.W.2d [288] at 293 [ (Tex.1995) ] (“The provision [article 8307c] has never been amended but has since been recodified without substantive change as sections 451.001-.003 of the Texas Labor Code.”).

Bouchet, 963 S.W.2d at 55-57.

For purposes of section 451.001(4), a benefit review conference is a proceeding under Subtitle A of the Workers’ Compensation Act. It is undisputed that Pamela Griggs attended David’s benefit review conference and verbally participated during the proceeding. The majority’s opinion recites as much. Subsections (c) and (d) of section 410.026 do not permit the benefit review officer to formally memorialize the verbal discussions of the parties and the participants, or formally memorialize whatever documents are produced by the parties and/or the participants. See Tex. Lab.Code Ann. § 410.026. Nevertheless, the entire process as set out in sections 410.021 through 410.034, and further illuminated by sections 141.1 through 141.7 of the Texas Administrative Code, clearly contemplates a free exchange of information with regard to the disputed claim, with input from any source the benefit review officer deems acceptable. See Tex. Admin. Code § 141.5(a)(4) (Participant includes “any other individual, at the discretion of the benefit review officer.”). Certainly Pamela Griggs was a “participant” during the benefit review conference and was apparently permitted by the benefit review officer to discuss the disputed issues, and ask and answer questions. See Tex. Admin. Code § 141.5(d)(4). Therefore, interpreting the phrase “testify or about to testify” in section 451.001(4) in the most narrow, “term of art” fashion creates disharmony and inconsistency in the Workers’ Compensation Act, and we may not so presume. See Tex. Gov’t Code Ann. § 311.021; Helena Chem., 47 S.W.3d at 493.

As noted above, when an employee’s claim is initially denied, it is mandatory that he/she participate in a benefit review *416conference. The provisions for a benefit review conference are found in Chapter 410 of Subtitle A. See Tex. Lab.Code ÁNN. §§ 410.001 — .308 (Vernon 2006). Of the three non-appellate administrative proceedings provided in Chapter 410 for seeking relief from a contested claim, only the benefit review conference does not permit the creation of a formal record. The other two, “Arbitration,” and “Contested Hearing,” permit the taking of sworn testimony and the memorialization of the proceedings similar to that in trial courts. See Tex. Lab.Code Ann. §§ 410.114, 410.164 (Vernon 2006). Ultimately, when a party has exhausted its administrative remedies under Subtitle A and is dissatisfied by the final decision of the appeals panel, the party may seek judicial review in a court of law. See Tex. Lab.Code Ann. § 410.251 (Vernon 2006).

For purposes of this appeal, the question is which is the more harmonious and consistent construction of section 451.001(4)— a fully prophylactic application by which an employee who verbally participates in any Subtitle A proceeding, including a benefit review conference, is included in the protected class; or the majority’s selective application in which a non-claimant employee’s verbal participation in the first mandated proceeding, “informal” though it may be, subjects the non-claimant employee to possible retaliatory discharge for having verbally participated? I must presume the Legislature intended the former construction of section 451.001(4) as it gives effect to the “entire statute” and evidences a more just and reasonable result. See Tex. Lab.Code Ann. § 451.001(4). Because the majority construes it otherwise, I respectfully dissent.