CRB Case Annotations re: Section 31-278

Respondents argued that trier lacked jurisdiction to decide whether claimant should be awarded total disability benefits in lieu of the “sick pay” compensation that was paid to him under a collective bargaining agreement, as Commission lacks jurisdiction over contractual issues such as reinstatement of sick time. CRB disagreed with respondents’ characterization of issue, as real question before trier was whether claimant was entitled to total disability benefits as a result of his compensable injury. Because he was so entitled, trier had authority to order their payment under § 31-307, and to ensure that they were paid properly (i.e., as non-taxable income) as mandated by law. Issue does not arise out of collective bargaining agreement, and was not a matter of contractual interpretation. See, Regan, § 31-300, § 31-307.

Pro se claimant attempted to argue on appeal that trier should have recused himself. As this point was not raised until after claimant received trier’s decision, CRB refused to consider argument, as the claimant could have raised the issue at trial. See, Napolitano, § 31-301. Factual findings, § 31-301-9, § 31-308(b).

CRB held that trier had jurisdiction to set forth procedural guidelines for calculating future versions of § 7-433b(b) cap, where permanency benefits would continue to be payable for several years following issuance of award. See, Demarest, § 7-433b.

CRB lacked jurisdiction to consider constitutionality of Social Security offset requirement in § 31-307(e). See, Rayhall, § 31-295, § 31-298; also cited at Rayhall, § 31-307, 31-308(b).

Decedent’s office was temporarily relocated to Connecticut headquarters of employer during the six weeks before his death. Employment relation must have a legal situs under choice-of-law rule enunciated in Cleveland v. U.S. Printing Ink, Inc., 218 Conn. 181 (1991), and largest percentage of employer-employee contacts occurred in Connecticut at time of injury. “Place of contract” test also discussed in footnote. See Owen, § 31-275(1), § 31-275(9).

CRB affirmed commissioner’s dismissal of shoulder injury claim on ground that res judicata precluded the claimant from relitigating that matter. Claim had been raised at earlier formal hearing, and evidence had been offered that made it ripe for determination, even though it was not explicitly decided in the earlier award. Distinctions between res judicata, collateral estoppel and “law of the case” discussed. Also cited at Schreiber, § 31-297.

CRB and Workers’ Compensation Commission have jurisdiction to consider due process issues, even though board may not determine constitutionality of statutes. See, Melendez, § 31-298, § 31-300, § 31-303; decision on motion in Melendez, 4178 CRB-2-00-1 (May 24, 2001) (claimant moved to correct/articulate CRB opinion), § 31-301. Appeal procedure.

CRB determined that trier had subject matter jurisdiction to issue a decision on § 31-303 penalties where parties failed to notify him that a settlement had been reached before he prepared and issued his ruling. Resolution of pending issues via mutual agreement must be ratified by commissioner once the case has begun. Supreme Court affirmed reasoning of CRB regarding jurisdiction, but reversed on the underlying issue of § 31-303’s applicability to late payments of attorney’s fee awards. See Schiano, § 31-303. See also, Schiano, cited at § 31-300; prior decisions in Schiano, 3436 CRB-4-96-10 (April 8, 1998), discussed at § 31-293, Schiano, 1852 CRB-4-93-9 (Dec. 7, 1994), aff’d., 57 Conn. App. 406 (2000), discussed at § 31-293 and § 31-301 Appeal procedure, and Schiano, 3315 CRB-4-96-4 (May 16, 1997), § 31-301 Appeal procedure.

CRB reversed trial commissioner’s granting of motion to dismiss all claims against respondent insurer Travelers for lack of subject matter jurisdiction. Trier was empowered to go beyond computer records of commission to consider whether payment of premiums following apparent cancellation date of policy established an insurance contract under common-law principles, as claimant’s compensation was still at issue, as was the possibility of fining the employer for not having insurance. DiBello, infra, this section, and Stickney v. Sunlight Construction Inc., 248 Conn. 754 (1999), discussed. Also cited at Bell, § 31-348.

Workers’ Compensation Commission has continuing jurisdiction over claims. Where previous trial commissioner found claimant totally disabled for a certain timespan, but failed to order the payment of total disability benefits, a subsequent trier had the authority to make that order. See, Moran, § 31-308a.

CRB ruled that trial commissioner had jurisdiction to consider whether common-law agency and contract principles establish an insurance contract between employer and prospective insurer on date of injury where no other insurer was on the risk, and the claimant’s compensation had not yet been fully determined and collected. Stickney v. Sunlight Construction, Inc., 248 Conn. 754 (1999), discussed. See also, DiBello, § 31-294c, § 31-301. Appeal procedure, § 31-301-9, § 31-348.

See, Rodriguez, § 31-294d.

In a footnote, CRB discussed the decisions of two panel members to recuse themselves from hearing the appeal at the request of the appellant. One such request was made over a month before oral argument, while the other was made at oral argument itself. With respect to the latter request, though no violation of the Code of Ethics for Workers’ Compensation Commissioners was apparent, the panelist agreed to recuse himself to expedite the resolution of this case. See also, Prioli, § 31-290a, § 31-301. Appeal procedure, § 31-301-9, § 31-315, § 31-327. Subsequent ruling in Prioli, 3955 CRB-6-98-12 (October 16, 2000), § 31-301c.

Commission lacked jurisdiction to interpret collective bargaining agreement once it was determined that the claimant was not entitled to benefits under § 31-284b. See also, Pascarelli, § 31-284b, § 31-287; prior decision in Pascarelli, 14 Conn. Workers’ Comp. Rev. Op. 328, 2115 CRB-4-94-8 (September 15, 1995), aff’d, 44 Conn. App. 397, 400 (1997), cited at § 31-287, § 31-310.

Kuban v. Bridgeport Hospital, 3926 CRB-7-98-6 (September 23, 1999), appeal dismissed, A.C. 20100 (January 5, 2000).

Though substantive issues of appeal (constitutionality of § 31-349c) were not within scope of board’s review, fact that appeal was from a Finding and Dismissal made it cognizable by CRB, allowing board to consider reserving case to Appellate Court under § 31-324. See also, Kuban, § 31-324, § 31-349.

CRB lacks jurisdiction over appeal taken directly from the opinion of a § 31-349 medical panel. Board also lacks authority to decide constitutionality of statutes. When considering issues of constitutional magnitude, CRB may only interpret existing statutes and cases in the manner most consistent with constitutional guarantees. See also, Fish, § 31-349.

Second Injury Fund argued that trial commissioner erroneously entered award against estate of deceased individual. CRB held that jurisdiction was established over employer prior to his death, and remedial purpose of Act is better served by holding that substitution of estate/administrator as respondent is automatic process. CRB relied on Matey v. Dember, 5 Conn. Workers’ Comp. Rev. Op. 104, 516 CRD-5-86 (June 14, 1998), aff’d in part and rev’d in part, 256 Conn. 456 (2001), in its decision. See, Kluttz, § 31-308(b) and (c). Prior decision in Kluttz, 10 Conn. Workers’ Comp. Rev. Op. 195, 1199 CRD-4-91-3 (November 5, 1992), aff’d, 228 Conn. 401 (1994), cited at § 31-278, § 31-355.

CRB lacks jurisdiction to decide constitutionality of § 31-349 as revised by P.A. 95-277. See also, Bass, § 31-349.

CRB does not have jurisdiction to consider the constitutionality of workers’ compensation statutes, in this case § 31-288. See also, Baribault, § 31-288, § 31-301-4, Correction of finding.

Trial commissioner found that claimant, a Connecticut resident who was injured at LaGuardia Airport in New York, had an office in his home and flew most of his routes out of Bradley Airport in Windsor Locks. He concluded that the place of the employment relation was Connecticut, and thus ruled this Commission had jurisdiction to entertain the instant claim. Affirmed. Facts were not challenged, and sufficed to support the trier’s conclusion, which satisfied the test enunciated in Cleveland v. U.S. Printing Ink, Inc., 218 Conn. 181 (1991). Subsequent decision in Genden, 3912 CRB-5-98-10 (July 22, 1999), § 31-349.

Claimant, a Connecticut resident, was injured while piloting a jet over Ohio airspace. AIA is based in Michigan. Trier found that Connecticut had jurisdiction over claim because employment contract was formed in Connecticut and this state was the place of the employment relationship. CRB affirmed. Sufficient evidence existed (particularly testimonial evidence) to support the trier’s findings. Subsequent decision in Burse, 3986 CRB-2-99-3 (March 3, 2000), § 31-284(a), § 31-301. Factual findings.

Spears v. Spears, 2082 CRB-2-94-6 (October 30, 1997), dismissed for lack of a final judgment, A.C. 17819 (January 15, 1998).

Claimant, a Narragansett Indian and resident of Rhode Island, claims to have fallen off a roof while working for a business operated out of the home of Lake and Keri Spears, a married couple living on the Mashantucket Pequot Indian Reservation. The reservation is a sovereign nation under the laws of Connecticut and the United States. Trial commissioner concluded that the claimant was not an employee under the Workers’ Compensation Act because he was not a state resident, did not suffer an injury in Connecticut, and worked for an alleged employer whose principal place of business was not in Connecticut. CRB, which has power to determine its own jurisdiction, analyzed the statute prescribing federal recognition of the tribe, and our Supreme Court’s decision in State v. Spears, 234 Conn. 78 (1995). After a detailed analysis of several statutes and case law, the majority ultimately determined that jurisdiction indeed existed under 40 U.S.C. § 290, which gives the authority charged with enforcing each state’s workers’ compensation law the power to apply such laws to all lands and premises owned by the United States. Indian reservations are held in trust by the United States. Therefore, the situs of the alleged injury creates subject matter jurisdiction in this Commission over the claim. (Frankl, C., dissenting) 40 U.S.C. § 290 should not be read as broadly as the majority concludes, as said law was intended to protect laborers and mechanics working on federal lands. Tribe may have other remedies for personal injuries, and without clear indication from Congress or the tribe itself, the Act should not be read to apply to work-related injuries occurring on a recognized reservation. See also, Spears, § 31-298.

Where 1990 injury was at issue, but compensability of 1992 injury was not before commissioner at formal hearing, “finding” that latter injury was unrelated to former injury was construed as mere advisory statement that no conclusion was reached regarding relationship of 1992 injury to 1990 injury. See also, Altamura, § 31-294c, and § 31-301. Appeal procedure.

Claimant attempted to introduce additional evidence regarding competency of commissioner. Sufficient information was not offered to make a § 31-301-9 ruling; moreover, CRB does not have authority to determine the competency of commissioners. See also, Bailey, § 31-298, and § 31-308a.

CRB affirmed trial commissioner’s conclusion that Connecticut lacked subject matter jurisdiction where trier found Tennessee was the place of the employment contract, the place of the employment relation and the place of the claimant’s injury.

CRB affirmed the trial commissioner’s determination that Kentucky, rather than Connecticut, properly has jurisdiction over the claim, as Kentucky has “the most significant relationship to the contract of employment” pursuant to the Restatement Second of Conflict of Laws. The undisputed facts in this case indicate that the claimant’s injury occurred in Kentucky, that the employer’s place of business was in Kentucky, and that the claimant was residing in Kentucky when the injury occurred. The only significant connection to Connecticut was the claimant’s acceptance of the offer of employment from Connecticut. CRB noted that this board had previously stated: “When the contract of employment between the parties was entered into in this state, our Workers’ Compensation Act is available to determine the compensability of the employee’s injury, regardless of the place of the employment relationship or the place of injury.” Casagrande v. Federal Express, 12 Conn. Workers’ Comp. Rev. Op. 170, 172, 1561 CRB-5-92-11 (April 29, 1994). However, due to the reconsideration of the legal analysis regarding the place of contract as it relates to jurisdiction as set forth in Quinn, infra, the CRB declined to follow a strict place of contract analysis.

Claimant’s attorney instructed treating physician not to answer questions at deposition based on patient/physician privilege. Respondents then sought to preclude use of his testimony or medical reports as evidence. Trial commissioner found deposition was not ordered pursuant to § 31-278, as subpoena was issued by respondents’ attorney. He ruled that respondents’ remedy was to proceed under § 51-85 if subpoena was being ignored. Held, although no order was issued under § 31-278, commissioner was not prevented by § 51-85 from ruling on treating physician’s refusal to testify on the basis of patient-physician privilege. § 51-85 makes use of superior court optional if witness fails to comply with subpoena. As for merits of objection, patient-physician privilege does not apply where someone makes a workers’ compensation claim and chooses a particular doctor as treating physician. Exclusion of evidence is a permissible sanction for failure to allow discovery.

CRB reversed commissioner’s decision which found jurisdiction over the claimant’s claim. Claimant was an Alabama resident, employed by an employer in Alabama, who was injured in Alabama. CRB held that the mere fact that the claimant entered into the employment contract while he was still a resident of Connecticut was not sufficient to allow Connecticut jurisdiction over the claim. Discussion of jurisdiction and case law.

Claimant was a Virginia resident employed by a Connecticut corporation. Contract was signed in Virginia. Claimant resided in Connecticut for two-week training session, and was then sent to West Africa to assume his supervisory duties. Claimant contracted serious illness in Africa. Trial commissioner concluded that Connecticut was place of employment relationship, but 1993 amendment to § 31-275 regarding non-resident employees precluded basing jurisdiction on that alone. Held, affirmed. 1993 amendment affects non-resident employees suffering out-of-state injuries by implication, even though it specifically addresses in-state injuries only. Unreasonable dichotomy in law would result otherwise. See also, Giordano, § 31-275(9).

See, Dixon, § 31-298 for discussion of jurisdiction over appeal from denial of motion to order deposition.

Claimant injured in 1987 at West Hartford job site. Neither claimant nor respondent corporation was domiciled in Connecticut. Claimant was hired in New York and performed most of his job services there. He received workers’ compensation under New York law. Commissioner found no jurisdiction existed under interest analysis theory. Held, Cleveland v. U.S. Printing Ink, Inc., 218 Conn. 181 (1991), applies to this injury; 1993 amendment to § 31-275 definition of “employee” not intended to apply retroactively. Under conflict of laws rule in Cleveland, jurisdiction exists because Connecticut was place of injury.

Trial commissioner properly ruled that Connecticut lacked jurisdiction over case under test in Cleveland v. U.S. Printing Ink, Inc., 218 Conn. 181 (1991), the applicable test at the time of injury. Injury did not occur in Connecticut, employment contract was entered into out-of-state, and alleged in-state employer was found to be neither the agent of Roberts nor the employer at time of injury.

Stickney v. Sunlight Construction Co., 12 Conn. Workers’ Comp. Rev. Op. 364, 1738 CRB-6-93-5 (August 2, 1994), rev’d, 48 Conn. App. 609 (1998), aff’d, 248 Conn. 754 (1999).

Trier erred in holding he lacked subject matter jurisdiction to resolve dispute between two insurance carriers where cancellation of one policy and effective coverage date of the other was not furnished to the workers’ compensation commission. Reversed by Appellate Court, which held that the trial commissioner lacked subject matter jurisdiction. See also, Stickney, § 31-315; See later, Stickney, 3205 CRB-6-95-11 (April 25, 1997), § 31-315, § 31-348.

Casagrande v. Federal Express, 12 Conn. Workers’ Comp. Rev. Op. 170, 1561 CRB-5-92-11 (April 29, 1994).

Remanded with direction for trial commissioner to apply the rules of contract formation (offer and acceptance) where trier found claimant entered a new contract of employment upon transferring to Kentucky. Trier must determine when and where the contract between the claimant and the employer was made. But see later decision, Casagrande, supra.

Santucci v. Remodeling Consultants, Inc., 12 Conn. Workers’ Comp. Rev. Op. 118, 1438 CRB-7-92-6 (February 28, 1994).

Trier properly dismissed claim where, on remand, trier found the place of the employment relationship at the time of claimant’s injury had shifted from Connecticut to New York. See, Santucci, 10 Conn. Workers’ Comp. Rev. Op. 66, 1140 CRD-7-90-11 (March 23, 1992).

Gibson v. Keebler Company, 12 Conn. Workers’ Comp. Rev. Op. 77, 1466 CRB-1-92-7 (February 4, 1994), aff’d, 37 Conn. App. 392 (1995).

Trial commissioner properly determined Connecticut was not the place of injury, place of the employment contract nor place of the employment relationship. Trier found claimant’s employment relationship indicated that although he had an office at his home in Connecticut, claimant had an Illinois office and initially accepted Illinois workers’ compensation benefits, and was responsible for sales in the employer’s Atlantic region.

Currier v. Retail Express, 11 Conn. Workers’ Comp. Rev. Op. 234, 1344 CRD-6-91-11 (November 8, 1993).

Trier found claimant, a long haul truck driver, did not have sufficient contacts with Connecticut to establish Connecticut jurisdiction. CRB remanded matter as trier failed to apply our Supreme Court’s ruling in Cleveland v. U.S. Printing Ink, Inc., 218 Conn. 181 (1991) to the facts found to determine if Connecticut was the place of the employment relation.

Schick v. Windsor Airmotive Division, 11 Conn. Workers’ Comp. Rev. Op. 17, 1033 CRD-1-90-6 (February 16, 1993), motion to dismiss appeal for lack of final judgment denied, 31 Conn. App. 819 (1993), aff’d, 34 Conn. App. 673 (1994).

CRB does not have the authority to compel a commissioner who has resigned to act on unfinished matters relating to a claim. See also, Schick, § 31-301. Appeal procedure.

Kluttz v. Howard, 10 Conn. Workers’ Comp. Rev. Op. 195, 1188 CRD-4-91-3 (November 5, 1992), aff’d, 228 Conn. 401 (1994).

See, Kluttz, § 31-355.

Romeo v. H & L Chevrolet, Inc., 10 Conn. Workers’ Comp. Rev. Op. 72, 1149 CRD-7-90-12 (March 31, 1992).

Where claimant’s request that trial commissioner should have recused himself in the proceedings below and the request for recusal was not an issue below or mentioned in claimant’s Reasons of Appeal but mentioned for the first time in appellant’s brief before the CRB; such request will not be considered for the first time on appeal. Also, as commissioner below was obligated to perform administrative functions and found no record of a notice of claim being timely filed nor did the commissioner’s actions result in claimant being denied his due process right to an impartial arbiter; CRB upheld trier’s decision. See also, Romeo, § 31-294c and § 31-301. Appeal procedure.

Santucci v. Remodeling Consultants, Inc., 10 Conn. Workers’ Comp. Rev. Op. 66, 1140 CRD-7-90-11 (March 23, 1992).

Remanded. Trier found he lacked subject matter jurisdiction as Connecticut was not the place of injury or the place of hire. However, trier must address whether Connecticut was the place of employment relation according to Supreme Court’s rationale in Cleveland v. U.S. Printing Ink, 218 Conn. 181 (1991).

Chute v. Mobil Shipping and Transportation Company, 9 Conn. Workers’ Comp. Rev. Op. 135, 1007 CRD-7-90-4 (May 22, 1991).

Matter reversed and remanded as trier failed to determine whether an employer-employee relationship existed at the time of decedent’s injury. The Supreme Court in Cleveland v. U.S. Printing Ink, Inc., 218 Conn. 181 (1991) prescribed a new rule for conflicts of law issues and held the Connecticut Workers’ Compensation Act should be applied when Connecticut is the place of injury, the place of the employment contract or the place of the employment relation. The court relied on Castro v. Viera, 207 Conn. 420 (1988) and its holding that in order for subject matter jurisdiction to be obtained, it must be found that an employer-employee relationship existed.

Taylor v. New Penn Motor Express, 9 Conn. Workers’ Comp. Rev. Op. 116, 950 CRD-2-89-11 (April 24, 1991).

Trial commissioner’s finding claimant was hired in Connecticut thereby satisfying Cleveland criterion is a factual finding which will not be disturbed on appeal. See, Cleveland v. U.S. Printing Ink, Inc., 218 Conn. 181 (1991).

Trantolo v. Trantolo & Trantolo, 8 Conn. Workers’ Comp. Rev. Op. 69, 823 CRD-6-89-2 (April 17, 1990).

Commission lacks jurisdiction to decide constitutional issues. See also, Trantolo, § 31-294c, § 31-300, § 31-301. Appeal procedure.

Cleveland v. U.S. Printing Ink, Inc., 7 Conn. Workers’ Comp. Rev. Op. 51, 680 CRD-2-88-1 (August 10, 1989), no error, 21 Conn. App. 610 (1990), aff’d, 218 Conn. 181 (1991).

Where trial commissioner finds employer-employee relationship exists and there were significant contacts with this jurisdiction, Motion to Preclude will lie. Allegation of improper venue incorrect as § 31-278 and § 31-294 permit notice and jurisdiction of claims with any commissioner. Supreme Court held jurisdiction under this act applies where Connecticut is the place of injury or the place of hiring or the place of employment relation. See also, Cleveland, § 31-294c.

Lustig v. C.N. Flagg Co., 7 Conn. Workers’ Comp. Rev. Op. 38, 658 CRD-1-87 (July 25, 1989).

Commissioner does not have jurisdiction to decide constitutional issues. See also, Lustig, § 31-284b.

Ramos v. General Dynamics Corporation/Electric Boat Division, 7 Conn. Workers’ Comp. Rev. Op. 17, 538 CRD-2-86 (June 26, 1989).

Remanded to conform with the Supreme Court’s ruling in McGowan v. General Dynamics Corporation/Electric Boat Division, 210 Conn. 580 (1989)(per curiam) with respect to overlapping jurisdictions involved, Connecticut Workers’ Compensation Act and federal Longshore and Harbor Workers’ Compensation Act.

Brennan v. General Dynamics Corporation/Electric Boat Division, 6 Conn. Workers’ Comp. Rev. Op. 155, 460 CRD-2-86 (April 28, 1989).

Remanded to conform with the Supreme Court’s ruling in McGowan v. General Dynamics Corp./Electric Boat Division, 210 Conn. 580 (1989)(per curiam). Overlapping jurisdictions, Conn. Workers’ Comp. Act and federal Longshore and Harbor Workers’ Comp. Act.

Falcigno v. Joseph Feldman, Inc., 6 Conn. Workers’ Comp. Rev. Op. 88, 733 CRD-3-88-5 (January 13, 1989).

See also, Falcigno, § 31-294c. Remanded. Jurisdictional issues raised.

Todd v. Jazlowiecki, 6 Conn. Workers’ Comp. Rev. Op. 9, 493 CRD-6-86 (August 26, 1988), no error, 20 Conn. App. 805 (1989)(per curiam).

Recusal denied where both sides alleged previous contacts with the trial commissioner. See also, Todd, § 31-294d, § 31-298.

Faraci v. Connecticut Light and Power Co., 5 Conn. Workers’ Comp. Rev. Op. 160, 508 CRD-2-86 (August 10, 1988), no error, 211 Conn. 166 (1989).

Commissioner had no jurisdiction to hear matter alleging the unconstitutionality of § 31-308(d)’s prohibition of awards for scars resulting from spinal surgery.

Matey v. Dember, 5 Conn. Workers’ Comp. Rev. Op. 104, 516 CRD-5-86 (June 14, 1988), appeal dismissed, 210 Conn. 626 (1989)(per curiam), aff’d in part and rev’d in part, 256 Conn. 456 (2001).

Commissioner lacks jurisdiction to decide whether a claim was timely filed against an estate where conclusion dependent upon probate law. Appeal to Supreme Court initially dismissed as premature pending resolution of further evidentiary proceedings. Supreme Court later held that, though workers’ compensation claims are categorically subject to § 45a-395 C.G.S. (the probate nonclaim statute), a commissioner has jurisdiction under § 31-355 to enter an award against an employer’s estate for the purpose of establishing the Second Injury Fund’s liability even if the claim is barred by the nonclaim statute. CRB thus had jurisdiction to enter award against estate as prerequisite to ordering fund to make payments.

DeLorenzo v. United Autoworkers, 5 Conn. Workers’ Comp. Rev. Op. 31, 400 CRD-1-85 (April 6, 1988).

Subject matter jurisdiction will not be determined solely on whether there was a Connecticut contract of employment.

Austin v. Roy Brothers, Inc., 4 Conn. Workers’ Comp. Rev. Op. 115, 342 CRD-6-84 (October 19, 1987).

In determining jurisdiction other factors besides the place of employment contract should be considered.

Repasi v. Jenkins Brothers, 4 Conn. Workers’ Comp. Rev. Op. 82, 227 CRD-4-83 (June 11, 1987), dismissed on other grounds, 16 Conn. App. 121 (1988), cert. denied, 209 Conn. 817 (1988).

Commissioners do not have jurisdiction to determine constitutionality of statutes.

Thomas v. Carpenter Technology Corp., 2 Conn. Workers’ Comp. Rev. Op. 127, 247 CRD-4-83 (May 13, 1985), cert. denied, 198 Conn. 804 (1986).

Commissioner vested with broad powers to carry out act including powers to secure evidence.

Sullivan v. Northwind Energy Insulators, Inc., 2 Conn. Workers’ Comp. Rev. Op.12, 146 CRD-4-82 (May 16, 1983), no error, 2 Conn. App. 689 (1984), cert. denied, 195 Conn. 801 (1985).

Where commissioner issued a finding and award after claimant initiated a writ of mandamus seeking a hearing on his motion to disqualify the commissioner, the issuance of the award was construed as a denial of the motion.

Baker v. Colt Industries, 2 Conn. Workers’ Comp. Rev. Op. 4, 106 CRD-1-81 (May 13, 1983).

Compensation Review Division has no jurisdiction to rule on a negligence claim that employer failed to provide prompt medical attention.

CRB Case Annotations re: Section 31-278

Jurisdiction/Disqualification.