Saint Joseph Hospital v. Angela Frye Honorable R. Scott Borders, Administrative Law Judge and Workers' Compensation…

Summary

The Kentucky Supreme Court held that Frye's earlier workers' compensation claim was no longer pending, for mandatory joinder purposes, after the final hearing and before the administrative law judge issued the decision. Because Frye's later injury occurred during that interval, KRS 342.270(1) did not bar her separate claim, and the court affirmed the Court of Appeals while remanding for a decision on the merits. The opinion also explained that its holding does not extend to claims pending on appellate review.