eNotes: Workers’ Compensation – April 2023 – Washington, DC

SIGNIFICANT CASE SUMMARIES

Washington, DC Case Summary

Schwechter v. DC. Dept. of Empl. Svcs.
District of Columbia Court of Appeals
No. 22-AA-007

Decided: January 5, 2023

D.C. Code § 32-1508(8), which deems settlements as final binding dispositions, does not permit modifying WCA lump-sum settlements.

Background

Claimant was injured while riding a bicycle during a work retreat. An ALJ denied the Claimants claim the injury occurred during an extracurricular activity, rather than arising out of and during the scope of his employment. Claimant appealed to the CRB. Prior to a hearing, the Employer and Claimant reached a lump-sum settlement, pursuant to D.C. Code § 32-1508(8) which deems settlements as final binding dispositions. The settlement would pay Claimant a lump-sum of $1,050,000 in exchange for absolute resolution of the claim. The agreement was a final binding disposition intended as a full payment barring all future recovery of benefits on the claim. Less than a year after the settlement was signed, the Claimant applied for a formal haring to modify the settlement because his condition had worsened. The CRB held that lump-sum settlements under D.C. Code § 32-1508(8) cannot be modified. Claimant appealed to the DC Court of appeals.

Holding

The DC Court of Appeals affirmed, finding that the lump-sum settlement agreement, entered into pursuant to D.C. Code § 32-1508(8), clearly and unambiguously barred any future recovery on the claim. The Court denoted that the CRB is not presumably correct simply because of its administrative statutes, disaffirming innate deference. Nevertheless, the Court held that the CRB correctly concluded that lump-sum settlements governed by D.C. Code § 32-1508(8) cannot be modified. Moreover, settlement agreements are treated the same as contracts, and unless they are found ambiguous, the written agreement governs each parties rights.

Based on its affirmative decision, the Court declined to answer whether D.C. Code § 32-1524(a) permits modification to lump-sum settlements.

Takeaway

D.C. Code § 32-1508(8), in conjunction with clear and unambiguous contract language, promotes finality in than lump-sum settlement agreements, as they are intended to be final binding dispositions.

Questions about this case can be directed to Jamie L. DeSisto, at (443) 641-0558 or jdesisto@tthlaw.com.