D'QUAIX v. Chadron State College

Sara D’Quaix, the claimant in this workers’ compensation proceeding, suffered a work-related injury, and her employer voluntarily paid indemnity benefits. After a trial in the Workers’ Compensation Court, D’Quaix was awarded further indemnity benefits. However, the award did not expressly grant her employer credit against the award for the voluntary payments it had already made. The issue presented in this appeal is whether D’Quaix’s employer is nonetheless entitled to credit for the voluntary payments it made before the award was entered or whether D’Quaix should receive a waiting-time…