CRB Case Annotations re: Section 31-284(b)
Self-insurance.
Anderson v. Colt Manufacturing Co., Inc., 14 Conn. Workers’ Comp. Rev. Op.
240, 1930 CRB-1-93-12 (August 15, 1995).
Self-insured Coltec sold Firearms Division, which subsequently became Colt’s;
Colt’s agreed to assume administration of Coltec workers’ compensation claims.
Colt’s (not self-insured) subsequently went bankrupt; Coltec argued that liability
for claims had been validly transferred to Colt’s, and should now pass to Second
Injury Fund in light of bankruptcy. Coltec also made estoppel argument based
on involvement of state Treasurer in purchase of Firearms Division. Held: self-insureds
cannot permanently relieve themselves of liability for existing claims. Commission
does not take self-insurance privilege lightly, and safeguards regarding financial
security of self-insureds would be compromised if transfers of liability were
allowed. Although contract may be valid as between Coltec and Colt’s, Coltec
is not completely exonerated from liability under these circumstances. Other
arguments of Coltec regarding estoppel, bankruptcy are moot.
