SAIF Corp. v. Coria

The board’s order imposing a penalty must “articulate a rational connection between the facts and the legal conclusions it draws from them.” Jenkins v. Bd. of Parole, 335 P.3d. 828 (2014).

Petitioner sought judicial review of a reversal of the penalty imposed by the Workers’ Compensation Board (“the board”) on Respondent for unreasonably terminating Petitioner’s disability benefits. Petitioner assigned error to the Court of Appeals’ finding that misconduct could not be imputed to Respondent because there was no evidence of the employer’s misconduct in the record. Petitioner argued that the Respondent “acted unreasonably," which supported the imposition of a penalty. Respondent argued its actions could not be held unreasonable based on facts known when the claim was processed. The board’s order imposing a penalty must “articulate a rational connection between the facts and the legal conclusions it draws from them.” Jenkins v. Bd. of Parole, 335 P.3d. 828 (2014). The Court found the board’s order was unclear, as reflected in the parties’ competing understanding of its legal basis. The Court reasoned that the board’s explanation was insufficient to show how evidence in the record supported the imposition of a penalty. The Court concluded the board’s imposed penalty was not supported by “substantial reason” because it failed to clearly explain its reasoning for the penalty. Reversed and remanded to the board.