NWCDN Members regularly post articles and summary judgements in workers’ compensations law in your state.
Select a state from the dropdown menu below to scroll through the state specific archives for updates and opinions on various workers’ compensation laws in your state.
Contact information for NWCDN members is also located on the state specific links in the event you have additional questions or your company is seeking a workers’ compensation lawyer in your state.
UTAH
TRENDS
UTAH COURT OF
APPELAS DECISION RE: LABOR COMMISSION AUTHORITY TO RESCIND PRIOR APPROVAL OF
SETTLEMENT AGREEMENT
Waxies Enterprises, Inc. v.
Halladay, 2025 UT App 7 (January 16, 2025)
After reaching a settlement of a
claim made for injuries suffered while on the job, which the Labor Commission
approved, the parties discovered they had different ideas about how to
interpret one of the agreement’s material terms. The employer moved to have the
Labor Commission either compel the employee to sign additional documents to
implement its understanding of the agreement or set aside the prior approval of
the agreement. The Labor Commission denied both requests. On appeal, the Utah
Court of Appeals affirmed the denial of the motion to compel but reversed the
denial of the motion to set aside. With respect to the latter, the court
reiterated prior precedent that the Labor Commission has continuing
jurisdiction that encompasses the authority district courts have under Rule 60
of the Utah Rules of Civil Procedure. The court went on to hold the Labor
Commission had the authority to rescind its prior approval of the settlement
agreement once it was presented with a substantial question as to whether there
had been a meeting of the minds on the material term at issue. Because the appeals Board ruled that it
lacked such authority, Utah Court of Appeals set aside that decision and
instructed the labor Commission to revisit the issue.
© Copyright 2025 by Ford G.
Scalley, Scalley Reading Bates Hansen & Rasmussen, P.C.