Termination of PTD benefits at retirement age ruled constitutional
Satterlee v. Lumberman's Mutual Casualty Co., No. DA 08-0307 (Mont. 11/03/09).
In a 5-2 decision, the Montana Supreme Court ruled that a workers' compensation statute that terminated permanent total disability benefits once a worker became eligible for retirement benefits did not violate the worker's equal protection or due process rights.
What it means: In Montana, PTD benefits may be terminated once a worker is eligible for retirement benefits. By definition, PTD benefits are meant to assist the claimant for her work life, and to achieve the purpose of PTD benefits, it is sufficiently rational that those benefits will terminate when actual wages would normally terminate -- upon retirement.
Summary: A former worker's PTD benefits were terminated when she became eligible for Social Security Retirement Insurance.
She argued that Montana's law unconstitutionally discriminated against her based on age. The Montana Supreme Court upheld the constitutionality of the law, finding it did not violate the worker's equal protection or due process rights.
Although the worker argued that a similar statute terminating permanent partial disability benefits was ruled unconstitutional, the Supreme Court explained that the rationales for PPD and PTD benefits are different. A PPD claimant will presumably return to work in a finite period of weeks and earn an income while a PTD claimant will not.
The court pointed out that there is no fundamental right to receive workers' compensation benefits and that the PTD termination statute was rationally related to its purpose of ending work-related wage loss benefits in conjunction with the end of an employee's working life cycle. This, explained the court, protects the financial viability of the workers' compensation system. The statute was rationally related to the purposes of the workers' compensation system and therefore was constitutional.
The court found no due process violation, finding the Workers' Compensation Act satisfied the quid pro quo aspect of the due process clause. The court explained that while the worker who suffers a work-related injury after becoming eligible for SSRI benefits may not be able to qualify for PTD benefits, she is still eligible for benefits sufficiently significant to satisfy the exchange in the types of benefits received.
The dissent explained that it would apply a "rational scrutiny with bite" approach. It disagreed with the court's analysis, stating that the majority employed a "toothless analysis that permits the legislature to advance the perfectly legitimate task of protecting the economic viability of the workers' compensation system through the illegitimate means of penalizing injured workers who have qualified for SSRI."
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December 17, 2009
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