Lewis Ex Rel. Brown v. Gilmore

MARY R. RUSSELL, Judge,

dissenting.

I respectfully dissent because I believe that the majority’s opinion wrongly permits the Lewises two remedies for a single injury by allowing that they can obtain a workers’ compensation award against the insured statutory employer and also pursue a civil action against the uninsured immediate employer. Contrary to the majority, I would not hold that section 287.280.11 allows the Lewises to pursue two remedies merely because the immediate employer lacked workers’ compensation insurance and can be sued in court under the provisions of the statute. Allowing pursuit of two remedies could lead to an impermissible double recovery that the election of remedies doctrine is designed to prevent.

“The election of remedies doctrine, a doctrine of estoppel, originates upon the theory that where a party has the right to pursue one of two inconsistent remedies and he makes his election, institutes suit, and prosecutes it to final judgment, he cannot thereafter pursue another and inconsistent remedy.” Whittom v. Alexander-Richardson P’ship, 851 S.W.2d 504, 506 (Mo. banc 1993) (internal quotations omitted). The doctrine prevents an injured party from collecting a double recovery for a single injury. Id. “ ‘In [its] abstract form, [the election of remedies doctrine] becomes merely a legal version of the idea that one can’t have his cake and eat it too.’ ” Id. (quoting Dan B. Dobbs, Remedies, § 1.5 at 14 (1973)).

*527Unlike the majority, I do not find that section 287.280.1 can be interpreted without consideration of the election of remedies doctrine. Interpretation of section 287.280.1 is guided by this framework:

In construing statutes, a court ascertains the intent of the legislature from the language used and gives effect to that intent. The provisions of a legislative act are not read in isolation but construed together, and if reasonably possible, the provisions will be harmonized with each other. Insight into the legislature’s object can be gained by identifying the problems sought to be remedied and the circumstances and conditions existing at the time of the enactment.

Bachtel v. Miller County Nursing Home Dist., 110 S.W.3d 799, 801 (Mo. banc 2003) (internal citations omitted).

Considering these rules of construction, I read section 287.280.1 together with section 287.040,2 which defines the workers’ compensation liability for a statutory employer when the immediate employer fails to carry workers’ compensation insurance. Under section 287.040.3, the “liability of the immediate employer shall be primary” when assessing workers’ compensation liability to the employee. Section 287.040.3 further provides that, in the event that any compensation is paid by those secondarily liable [e.g. when the compensation is paid by the statutory employer because the immediate employer was uninsured], the compensation paid by the party not primarily liable “may be recovered from those primarily liable.”

The legislative intent of section 287.280.1 is to ensure an avenue for a workers’ compensation claimant to pursue compensation when an employer fails to carry workers’ compensation insurance. But the statute’s purpose is not to allow an additional avenue to pursue double compensation for the same injury simply because the immediate employer fails to carry workers’ compensation insurance and there is another employer who can be pursued for a remedy. Instead, considering the compensation-recovery remedy available under section 287.040 together with the language of section 287.280.1, the optional remedy that remains in this case is not that the Lewises can collect another monetary award via a civil action but rather is that the insured statutory employer will seek recovery against the uninsured immediate employer.

The majority makes much of the fact that there are two distinct employers at issue in this case who were subject to two different remedies pursued by the Lew-ises — both the uninsured immediate employer who was sued in a civil action and the insured statutory employer who was ordered to pay workers’ compensation. The presence of two employers, however, does not mean there are two injuries at issue that would overcome the double-compensation concerns sought to be addressed by the election of remedies doctrine — the Lewises sought redress for the same injury in both the civil action and the workers’ compensation proceedings.

The majority also suggests that to prevent the Lewises’ civil action removes the incentive that the immediate employer has to provide required workers’ compensation insurance. But to the extent that the immediate employer’s willingness to carry workers’ compensation insurance is motivated by the financial implications of facing possible litigation, there remains a monetary incentive for the immediate employer to carry insurance. Even without a civil suit brought by the Lewises, the im*528mediate employer still faces financial consequences because the statutory employer can seek redress for the workers’ compensation payment that was awarded to the Lewises.

For these reasons, I would affirm the trial court’s judgment.

. All references to section 287.280 are to RSMo 2000.

. All references to section 287.040 are to RSMo Supp.2011.