SW Legal studies in Business

Courts Defer To Agency Expertise in Absence of Conflict with Legislative Meaning

Appeals court upheld the decision of a workers’ compensation board. The court noted that the board’s interpretation of the law was not inconsistent with the plain meaning of the law, so the court must defer to its decision.

Topic Administrative Law
Key Words

Interpretation; Arbitrary and Capricious; Workers’ Compensation

C A S E   S U M M A R Y

Murphy was a pro hockey player with the Washington Capitals. During the season, he traveled with the team to New York for a game. Due to an injury, he did not play in the game. After the game, he went on a drinking binge with other players. When a bar closed, he tried to get a woman to go with him in his limo back to his hotel. A man with the woman hit Murphy over the head with a bottle; that injury required medical attention. The team cut Murphy, who collected $900,000 a year for the next three years despite not playing. He filed for workers’ compensation benefits, contending that the injury received in New York was in the course of employment. The administrative law judge (ALJ) rejected the claim, holding that his employment did not require him to get drunk and grab women. Murphy appealed to the Compensation Review Board that the Collective Bargaining Agreement (CBA) between the hockey players and the league stated that a player who travels with a team, but does not play due to an injury, is considered to be performing services for the team and due compensation. The Board held that its decision did not depend on the terms of the CBA. The ALJ’s decision properly followed the Workers’ Compensation Act. Murphy appealed.


Affirmed. The Board’s ruling that the Workers’ Compensation Act does not require the Board to interpret or enforce employment agreements outside of the coverage provided by the Act was not arbitrary, capricious, or an abuse of discretion. Courts defer to a reasonable construction of a statute that is made by an agency. The determination of the agency is binding on the appellate court unless it conflicts with the plain meaning of the statute or its legislative history.


Murphy v. D.C. Dept. of Employment Services, 935 A.2d 1066 (Ct. App., D.C., 2007)

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