SAIF v. CoriaAnnotate this Case
Claimant Hipolito Coria sought review of the Court of Appeals’ decision reversing a penalty that the Workers’ Compensation Board imposed on respondent SAIF for unreasonable claims processing. The board imposed the penalty pursuant to ORS 656.262(11)(a), which provides, in part, that, if an “insurer . . . unreasonably refuses to pay compensation,” the insurer “shall be liable for an additional amount up to 25 percent of the amounts then due,” plus penalty-related attorney fees. On review, the parties disagreed about the board’s reason for imposing the penalty. They also disagreed about many of the procedural and substantive legal requirements for imposing penalties pursuant to ORS 656.262(11)(a). The Oregon Supreme Court concluded the board’s imposition of the penalty was not supported by substantial reason because the board’s order failed to “articulate a rational connection between the facts and the legal conclusions it draws from them.” Consequently, the Court reversed and remanded the case to the board to explain its reasoning; necessarily, the Court did not reach the parties’ arguments about the legal requirements for imposing penalties pursuant to ORS 656.262(11)(a).