In Am. Motorists Ins. Co. v. Fodge, 63 S.W.3d 801 (Tex. 2001), the Texas Supreme Court recognized that the Texas Workers' Compensation Act vests the power to award workers' compensation benefits solely in the Workers' Compensation Commission,1 subject to judicial review. Id. at 803. It explained that the Commission has jurisdiction over disputes concerning income benefits, and the decision of its hearing officer is final unless it is appealed. Id. It further explained that allowing courts to award damages for wrongful deprivation of benefits circumvents the Commission's jurisdiction and is not permitted. Id. at 804. "Just as a court cannot award compensation benefits, except on appeal from a Commission ruling, neither can it award damages for a denial in payment of compensation benefits without a determination by the Commission that such benefits were due." Id.