Stricklen v. Multiple Injury Trust Fund

Summary

The Oklahoma Supreme Court held that the phrase “subsequent employer” in 85A O.S.Supp.2019 § 32 means the employer at the time of the employee’s subsequent injury—the employer for the last injury—not a different employer. Because that construction defeats the MITF’s basis for dismissal, the Court reversed the Workers’ Compensation Commission’s order and remanded for further proceedings. The Court also declined to decide the parties’ constitutional challenge, finding the statutory construction resolves the dispute without addressing the alleged special‑law violation.