Bryce Warnke-Green v. Pro-West Contractors, LLC and Liberty Northwest Insurance Company

Summary

The Alaska Supreme Court held that the Workers’ Compensation Appeals Commission has implied authority to reconsider non-final orders because that authority is necessarily incidental to its express power to issue appropriate orders. It reversed the Commission’s attorney-fee award because the Commission improperly considered the underlying Board litigation and settlement offers, reduced the hourly rate without evidentiary support, and disallowed one time entry without support. The case was remanded for an award of fully compensable and reasonable fees.