Abrams v. Ohio Pacific Express

The principal opinion acts as if the Missouri precedents — admittedly on all fours with this case — are trivial. In fact, the principal opinion is contrary to a long line of cases, to key concepts of Missouri administrative law, and to the rules of statutory construction.

I. History of “Filing” Rules in Worker’s Compensation Cases

Shortly after the enactment of the Worker’s Compensation law, the Kansas City *344Court of Appeals, in 1931, reviewed the predecessor to § 287.480, and held that an application for review “received” by the commission after the statutory period for appeal may be “refused…