Utah Labor Commission Has Broad Statutory Authority to Correct Old Workers Compensation Judgments

In Frito-Lay v. Labor Commission, the Utah Supreme Court clarified that, although Utah state courts do not have authority to impose the Utah Rules of Civil Procedure on administrative proceedings, the Utah Workers’ Compensation Act gives the Labor Commission broad authority to correct orders even after statutory appellate deadlines have passed. Accordingly, in Frito-Lay, the Supreme Court ruled that the Labor Commission could properly review an order that “did not reflect the [Administrative Law Judge’s] determination at the hearing” even after the “30-day deadline [for an appeal] provided by the Utah Administrative Procedures Act” had passed.