Shearer’s Food v. Hoffnagle

A single document may function as both an acceptance and a denial [of a worker's compensation claim]. Stockdale v. SAIF, 192 Or. App. 289, 84 P.3d 1120 (2004).

Employer appealed a judgment by the Worker’s Compensation Board.  Employer assigned error to the Board’s determination that Employer had accepted Claimant’s worker’s compensation claim concerning an original injury in the context of a letter denying a new injury.  On appeal, Employer argued that the letter was solely a denial of the new injury and never accepted the original injury.  A single document may function as both an acceptance and a denial.  Stockdale v. SAIF, 192 Or. App. 289, 84 P.3d 1120 (2004).  The Court held that because a single document may function as both an acceptance and a denial, there was substantial evidence to find that the Board could have reasonably concluded the letter was an acceptance of Claimant’s claim for the original injury because the letter stated that “[a]ll benefits will be paid on [Claimant’s] prior claim” and “[Employer] hereby issue[s] a denial of the new injury.”  Affirmed.