Utah State Insurance Fund v. Dutson

In Utah State Insurance Fund v. Dutson, 646 P.2d 707 (Utah 1982), an employee suffered a severe burn during employment. She did not file a formal claim for compensation with the Commission; but, as here, the necessary employer, physician, and insurer forms were filed, and the insurer accepted liability and paid compensation benefits and medical costs. Later, the employee required further surgery. The Commission denied a request for medical benefits for the surgery on the ground that because the applicant had not initially made a formal filing, the Commission had no jurisdiction. The Court held that the Commission had jurisdiction: Notwithstanding the fact that the workers' compensation statutes require either the filing of a claim for compensation or the filing of a written notice of the accident in order to invoke the jurisdiction of the Commission, this Court has long recognized that a claim for compensation need not bear any particular formality. In fact, "great liberality as to form and substance of an application for compensation is to be indulged." However informal the claim may be, it need only give "notice to the parties and to the commission of the material facts on which the right asserted is to depend and against whom claim is made." (Id. at 709 .) Dutson and its predecessors held that the Commission has jurisdiction over a workers' compensation claim on the basis of an informal filing--in Dutson's case, the filing of an employer's "First Report of Injury, " a physician's medical report, and an employer's notice of payment of compensation. See Dutson, 646 P.2d at 708-09. The Court further stated: The content of the several documents filed with the Commission reveal that all interested parties . . . were on notice of Dutson's claim and were duly apprised of the material, jurisdictional facts upon which the claim was based. . . . We therefore conclude that the form and substance of the documents filed with the Commission were adequate within the meaning, purpose and intent of the statutes, . . . to confer jurisdiction upon the Commission. (Id. at 709.)