Craven v. Fulton Sanitation Service, Inc.

Annabelle Clinton Imber, Justice,

concurring. As the majority points out, to apply collateral estoppel, four elements must be satisfied: (1) the issue sought to be precluded must be the same as that involved in the prior litigation; (2) the issue must have been actually litigated; (3) the issue must have been determined by a valid and final judgment; and (4) the determination must have been essential to the judgment. Beaver v. John Q. Hammons Hotels, 355 Ark. 359, 138 S.W.3d 664 (2003). Appellant in the case before the Workers’ Compensation Commission sought damages for his lumbar strain and herniated disc injuries. In the Workers’ Compensation Case, the ALJ made the following findings:1

The claimant has failed to prove that he sustained any “compensable injury” to his lower back or lumbar spine, either in the form of a lumbar strain or a (sic) two herniated discs, in the specific employment related incident (MVA) of March 10, 1999. He has failed to prove that the medically diagnosed injury of a lumbar strain is based upon or supported by any objective findings, as required by Ark. Code Ann. § ll-9-102(5)(D).2 He has failed to prove that the medically diagnosed and objectively documented injury or defect of two herniated lumbar discs were in any way causally related to the specific employment related incident (MVA) on March 10, 1999. Therefore he has failed to prove that such an injury or defect arose out of and occurred in the course of his employment, was due to a specific incident, and is identifiable by time and place of occurrence, Ark. Code Ann. § 11 — 9— 102(5) (A) (i).3

(Emphasis added.) As demonstrated by the order, the ALJ concluded that the injury of two herniated lumbar discs was not causally related to the motor vehicle accident on March 10,1999. With regard to the lumbar strain, however, the ALJ concluded that Appellant faded to prove that the medically-diagnosed injury of a lumbar strain was based upon or supported by any objective findings, as required by section 11-9-102(4) (D). Unlike the ALJ’s finding pertaining to the herniated discs, the finding concerning the lumbar strain does not address the issue of causation. Indeed, the ALJ acknowledged that “the medical evidence may have established that the [Appellant] experienced a lumbar strain in the motor vehicle accident of March 10,1999 . . ..” Therefore, the issue of whether Appellant’s lumbar-strain injury was caused by the automobde accident has yet to be determined.

In the subsequent lawsuit filed against Appellee, Appellant alleges in his second amended complaint that “as a direct result and proximate consequence of the negligent acts of the [Appellee], the [Appellant] sustained serious injuries, both temporary and permanent to his lumbar spine . . . .” (Emphasis added). As noted by the ALJ, injuries to the lumbar spine included injuries in the form of a lumbar strain and two herniated discs. Here, the ALJ made a specific finding of no causal relationship between the herniated-disc injuries and the motor vehicle accident, but he explicitly declined to make a similar finding in connection with the lumbar-strain injury. In the absence of any such finding, collateral estoppel does not preclude subsequent litigation on whether the lumbar-strain injury was caused by the automobile accident.

Moreover, workers’ compensation cases in which damages are adjudicated separately for each type of bodily injury are not preclusive in subsequent actions at iaw. In Heine v. Simon, 674 N.W.2d 411 (Minn. Ct. App. 2004), the Minnesota Court of Appeals held that the elements of collateral estoppel were not satisfied due to the distinction between how claims are adjudicated in workers’ compensation proceedings and how causes of action are litigated in courts of law. In so holding, the court said:

The issue of liability for damages, such as lost wages, is not litigated in workers’ compensation proceedings. See Katzenmaier v. Doeren, 150 Minn. 521, 522-23, 185 N.W. 938, 938 (1921). Workers’ compensation actions generally determine the amount of workers’ compensation benefits for which an employer is liable when an employee is injured during the scope of employment. See Minn. Stat. § 176.021, subd. 1 (2002).

Id. at 422. The Heine court concluded that the issues adjudicated “in the workers’ compensation action were factually dissimilar from those litigated in district court.” For that reason, the collateral estoppel doctrine did not preclude subsequent litigation.

A similar distinction can be made in this case. The Workers’ Compensation Commission made a separate “compensability” determination for each alleged injury sustained by Appellant; that is, the Commission determined whether Appellant sustained a “compensable” neck injury, upper back injury, or lower back injury. The issues before the circuit court would not be determined on the basis of each alleged injury; rather, the jury would be asked to determine (1) whether Appellant has sustained damages; (2) whether Appellee was negligent; and (3) whether such negligence was a proximate cause of Appellant’s damages. See, e.g., AMI Civil 2004, 203. In other words, the circuit court would instruct the jury to determine what injuries, if any, were caused by the automobile accident. Thus, the injury claims adjudicated in this workers’ compensation proceeding are factually dissimilar to those that would be presented in Appellant’s action at law against Appellee.

For the above stated reasons, I agree that we should reverse the order of summary judgment and remand for further proceedings. However, I decline to join the majority in resolving the issue of whether the circuit court’s order violates Appellant’s constitutional right to a jury trial under Article 2, Section 7 of the Arkansas Constitution. This court has a well-settled principle that we will avoid resolving a constitutional issue if it is not essential to deciding the case. Landers v. Jameson, 355 Ark. 163, 132 S.W.3d 741 (2003); Virden v. Roper, 302 Ark. 125, 788 S.W.2d 470 (1990); Board of Equal. v. Evelyn Hills Shopping Center, 251 Ark. 1055, 476 S.W.2d 211 (1972).

These findings by the ALJ were thereafter adopted by the Full Commission.

The cited statutory provision now appears at Ark. Code Ann. § ll-9-102(4)(D) (Repl. 2002).

Similarly, the cited statutory provision now appears at Ark. Code Ann. § 11-9-102(4)(A)(i) (Repl.2002).