Kenneth Monzulla, Appellant v. Voorhees Concrete Cutting and Alaska National Insurance Company, Appellees

Summary

The Alaska Supreme Court held that the Workers' Compensation Appeals Commission had implied jurisdiction to review an interlocutory Board venue order before a final Board decision. That authority was necessarily incident to the Commission's express appellate jurisdiction because delayed review could render important issues meaningless and discretionary review furthered the statutory goals of efficiency, reduced costs, and consistent precedent. The court also held that the Commission had authority to stay the venue proceedings and that Monzulla's subject-matter-jurisdiction challenge was timely, although any error in the Commission's refusal to consider it earlier was harmless.