The legal doctrine of res judicata provides that a valid and final judgment is conclusive between the same parties. It essentially bars a party from raising the same claim twice against the same defendant. In workers’ compensation cases, a judgment denying benefits is barred by res judicata after the claimant has exhausted his rights of appeal.
The Third Circuit Court of Appeal recently addressed this issue. Claimant was a Louisiana resident who was injured in an automobile accident while driving to work at a well-site in North Dakota. A claim was filed on Claimant’s behalf with the North Dakota Workforce, the body that regulates workers’ compensation claims in North Dakota. North Dakota Workforce found that the accident was caused by Claimant’s use of drugs and alcohol, and that his injuries did not arise out of the course and scope of his employment. Claimant was denied benefits, and the decision was not appealed or otherwise challenged.
Thereafter, Claimant filed a claim for workers’ compensation benefits in Louisiana. Employer filed an exception of res judicata, arguing that the proceeding before North Dakota Workforce precluded Claimant’s action in Louisiana. The workers’ compensation judge denied the exception of res judicata, and Employer appealed. Employer argued that because Claimant’s claim for compensation had already been decided by North Dakota Workforce, the doctrine of res judicata bars re-litigation of Claimant’s workers’ compensation claim in Louisiana.
Claimant maintained that the exception was properly denied. He argued that in addition to the distinctions between workers’ compensation laws in Louisiana and North Dakota, he also did not file a claim for benefits under North Dakota law – the claim was filed on his behalf. He had no notice of the decision denying him benefits, and he should be afforded an opportunity to rebut the presumption that he was intoxicated.
The Court of Appeals upheld the workers’ compensation judge’s denial of the exception of res judicata. Because Claimant did not participate in the workers’ compensation proceedings in North Dakota in any fashion, and this lack of participation was not intentional, there were exceptional circumstances that warranted relief from the preclusive effect of res judicata.
Richard v. Quality Const. & Production, LLC