We accepted review of this appeal to determine whether, when a workers’ compensation settlement involving an employee represented by counsel is approved by the Department of Labor and the SD-1 form is submitted contemporaneously with the settlement agreement, a court may set the settlement aside as non-final based on the court’s determination that the SD-1 form was not “fully completed.” We hold that when the Department of Labor approves a settlement, it implicitly approves the accompanying SD-1 form, and a court has no authority to set the settlement aside based on its independent finding that the SD-1 form was not “fully completed.” We therefore reverse the judgments of the Panel and of the trial court and dismiss the employee’s petition.
Case Number
M2011-00187-SC-WCM-WC
Originating Judge
Judge Joe P. Binkley, Jr.
Case Name
Christopher Furlough v. Spherion Atlantic Workforce, LLC
Date Filed
Dissent or Concur
No
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