Does Utah's workers' compensation reporting deadline run from injury or discovery? Darden Restaurant v. Labor Commission Explained

The Utah Court of Appeals recently clarified a crucial timing issue in workers’ compensation law, holding that the 180-day reporting deadline runs strictly from the date of injury, not from when an employee discovers the injury’s work-related nature.

Background and Facts: Chinyu James Sun, a restaurant manager, suffered neck and shoulder injuries in a July 2020 workplace slip-and-fall. He never filed an accident report with his employer, Darden Restaurant, claiming only to have left an ambiguous voicemail. Sun didn’t file a workers’ compensation claim until April 2021—some 300 days after the incident. The administrative law judge initially dismissed both claims as untimely, but the Utah Labor Commission’s Appeals Board distinguished between the injuries, awarding benefits for the neck injury based on when Sun allegedly became aware of its causal connection to his work accident.

Key Legal Issues: The central question was whether Utah Code § 34A-2-407’s reporting statute requires notice within 180 days of the injury date or within 180 days of when the employee discovers the injury’s work-related nature. The Labor Commission relied on the outdated precedent in Interstate Electric Co. v. Industrial Commission to apply a discovery rule.

Court’s Analysis and Holding: The Court of Appeals applied correctness review to the statutory interpretation issue and rejected the Commission’s approach. The court emphasized that the current reporting statute plainly states claims are barred if not reported “within 180 days of the day on which the injury occurs.” Significantly, the legislature had removed language from earlier versions of the statute that allowed for prejudice-based exceptions. The court noted that Utah’s Occupational Disease Act expressly includes discovery language (“knows or in the exercise of reasonable diligence should have known”), demonstrating the legislature knows how to include such exceptions when intended.

Practice Implications: This decision reinforces the strict nature of Utah’s workers’ compensation reporting deadlines. Practitioners must counsel clients that the 180-day period begins running immediately upon injury, regardless of the employee’s awareness of work-relatedness or causation. The ruling also highlights the importance of distinguishing between different statutory schemes within Utah’s labor code, as the Occupational Disease Act contains discovery provisions that the Workers’ Compensation Act lacks.