Sentry Casualty Company v. Bravin – 05-23-00869-CV – Jun 21, 2024

The 5th Court of Appeals (Dallas) reversed the judgment of the trial court regarding determination of attorney’s fees under Texas Labor Code § 417.003(a)(1). The Court concluded that because Workers-Compensation-Carrier conveyed its entire subrogation cause of action and lien to Third-Party-Claim-Carrier, Plaintiff-Employee nonsuited their third-party claims, the trial court erred by ruling that Workers-Compensation-Carrier owed any attorney’s fees to Plaintiff-Employee. The Court noted that nothing in Chapter 417 addresses purchase or sale of the carrier’s lien.

In re Recess Arcade Bar LLC – 03-24-00230-CV – Jun 19, 2024

The 3rd Court of Appeals (Austin) affirmed the trial court’s order denying Defendant-Employer’s plea to the jurisdiction. The Court reasoned that exhausting administrative remedies was not necessary because “[t]here is no aspect of the personal injury suit that requires [Plaintiff-Employee] to ultimately be eligible for workers’ compensation benefits.”

Lubbock County v. Reyna – 692 S.W.3d 853 – Jun 10, 2024

The 7th Court of Appeals (Amarillo) reversed the lower courts denial of Defendant-Carrier’s summary judgment asserting that Plaintiff-Employee was not entitled to both temporary income benefits (TIBs, IIBs, and SIBS) as well as permanent income benefits (LIBs). The Court concluded that Tex. Lab. Code § 401.011(25) precludes the payment of temporary income benefits and permanent income benefits for the same period because the payment of each type of income benefit is “a payment made to an employee for a compensable injury.”