Declaratory Judgment: Workers' Compensation Court

MONTANA SUPREME COURT DECISIONS

Thompson v. State, 2007 MT 185, 338 Mont. 511, 167 P.2d 867 Since the WCC does not appear in the list of courts of record enumerated in this statute, it cannot be “read into” the list. The fact that MAPA requires stenographic records is not sufficient to transform the WCC into a court of record for purposes of § 27-8-201, MCA. The WCC and other administrative tribunals may produce records which this Court or a district court may review on appeal. However, courts that produce records are not the same as courts of record, and the WCC is not presently authorized to issue declaratory judgments under the UDJA and § 27-8-201, MCA.

Thompson v. State, 2007 MT 185, 338 Mont. 511, 167 P.2d 867 The history of the WCC and the statute providing for exclusive jurisdiction in that court “to make determinations concerning disputes underSince the WCC does not appear in the list of courts of record enumerated in this statute, it cannot be “read into” the list. The fact that MAPA requires stenographic records is not sufficient to transform the WCC into a court of record for purposes of § 27-8-201, MCA. The WCC and other administrative tribunals may produce records which this Court or a district court may review on appeal. However, courts that produce records are not the same as courts of record, and the WCC is not presently authorized to issue declaratory judgments under the UDJA and § 27-8-201, MCA. [the WCA],” § 39-71-2905(1), MCA, indicates that the jurisdiction of the court goes beyond the minimum whenever the dispute is related to benefits payable to a claimant. However, this does not mean that the WCC may issue declaratory rulings outside the context of a dispute concerning benefits.

Thompson v. State, 2007 MT 185, 338 Mont. 511, 167 P.2d 867 Where no benefits are at issue, the WCC does not have jurisdiction to issue a declaratory judgment holding §§ 39-71-604(3), 50-16-527(5), MCA, unconstitutional.

Thompson v. State, 2007 MT 185, 338 Mont. 511, 167 P.2d 867 The WCC does not have jurisdiction to issue a declaratory judgment ruling in the particular context of this case. Unlike the general jurisdiction granted to district courts over “all cases in law and in equity,” the WCC is a court of limited jurisdiction. It is an administrative tribunal governed by MAPA and allocated to the Department of Labor and Industry for administrative purposes. As such, courts of limited jurisdiction have only such power as expressly conferred by statute, and the applicable statutes here (§§ 2-4-501, 39-71-2905(1), MCA) authorize the WCC to issue declaratory rulings only in the context of a dispute concerning benefits under the Workers’ Compensation Act and only as to the applicability of any statutory provision, rule, or order of the agency to that dispute.

 
MONTANA WORKERS' COMPENSATION COURT DECISIONS
Robinson v. Montana State Fund [12/31/08] 2008 MTWCC 55 Pursuant to Thompson v. State of Montana, 2007 MT 185, 338 Mont. 511, 167 P.3d 867, for this Court to have subject matter jurisdiction to hear a declaratory judgment action, there must be a dispute concerning benefits and the declaratory judgment sought must be within the context of that dispute. In the present case, Petitioner’s disputed benefit has no relation to the declaratory judgment sought and it is therefore insufficient to confer jurisdiction on this Court.