Ryan's Family Steak Houses, Inc. v. Gowan

ANNUNZIATA, Judge.

Ryan’s Family Steak Houses, Inc. (“RFS”) and its insurance carrier appeal the Workers’ Compensation Commission’s decision affirming the deputy commissioner’s finding that appellants had made a de facto award to appellee, Brenda Gowan, by paying her disability benefits for a period of sixteen weeks without filing a memorandum of agreement with the commission. On appeal, RFS contends 1) the finding of a de facto award lacks statutory authorization; 2) the doctrine of defacto *461awards is unconstitutionally vague, because it is subject to arbitrary application by the courts; and…