Mattson v. Department of Labor and Industries of Wash.

Background

A Washington worker injured his arm on February 7, 1927, and later accepted a final payment of $240 on January 17, 1928 that closed his case. At the time of the injury the law allowed reopening awards for aggravation, but the statute was amended on March 15, 1927 to require that a beneficiary apply within three years. In May 1933 the worker asked the state agency to reopen his claim for increased benefits; the agency dismissed it as barred by the three-year limit, and Washington’s courts affirmed that dismissal before the case reached this Court.

Reasoning

The central question was whether the 1927 time limit unlawfully took away a vested property right in violation of the Constitution’s due process clause. The Court explained that Washington’s workers’ compensation system is compulsory, replaces common-law lawsuits with a statutory remedy, and pays claims from a state-administered fund. The Court said the State may impose reasonable conditions on how claims are asserted and that limiting the time to seek readjustment affects only the remedy. Because the three-year restriction was not shown to be unreasonable, arbitrary, or oppressive, it did not violate due process, and the lower courts’ judgment was affirmed.

Real world impact

The decision permits states to enforce reasonable deadlines for reopening settled workers’ compensation awards. Injured workers who wait beyond the state’s deadline risk losing the chance for additional payments for later aggravation. The ruling preserves the State’s ability to structure and limit procedural claims under its compensation system.