## Facts

- Heather (plaintiff) was the infant, illegitimate daughter of Bryan, an employee of Delta Drilling Company (Delta) (defendant).
- Bryan was killed in an accident arising out of and in the course of his employment with Delta when Heather was only a few months old.
- A claim for Wyoming workers’ compensation death benefits was filed on Heather’s behalf.
- At the time of Bryan’s death, Bryan had not provided financial support to Heather or to Heather’s mother during pregnancy.
- Delta opposed the claim, relying on an earlier Wyoming Supreme Court decision (from 1938) that had been read to limit workers’ compensation death benefits to legitimate children.
- Delta also argued that, even if illegitimate children could qualify, benefits were payable only if the child was actually dependent on the deceased worker, and Heather could not show actual dependency because Bryan had provided no support.
- The trial court agreed with Delta’s arguments and granted summary judgment for Delta, effectively denying Heather’s claim as a matter of law.
- Heather appealed to the Wyoming Supreme Court.

## Issues

1. Whether Wyoming’s workers’ compensation scheme may be applied to categorically exclude an illegitimate child from death benefits solely because of illegitimacy.
2. Whether summary judgment was proper where questions remained about Heather’s ability to qualify as Bryan’s child and as a dependent for purposes of death benefits.

## Decision

- The Wyoming Supreme Court reversed the summary judgment and remanded for further proceedings.
- The court rejected a categorical rule that illegitimate children are never eligible for workers’ compensation death benefits.
- The court held the workers’ compensation provisions must be construed to allow an illegitimate child to seek benefits upon proper proof (including proof of parentage and satisfaction of statutory requirements related to the claim).
- The court concluded it was error to dispose of Heather’s claim by summary judgment because the governing law could not be applied as an automatic bar, and additional factual and legal matters remained for determination on remand.

## Legal Principles

- A workers’ compensation statute and related constitutional provisions should be construed liberally to carry out the remedial purpose of providing support to a deceased worker’s dependents.
- A classification that denies benefits to children solely because they are illegitimate raises serious equal-protection concerns; courts should avoid interpretations that impose an automatic exclusion on that basis.
- Illegitimate children may be treated as potential beneficiaries of workers’ compensation death benefits when the parent-child relationship is properly established and statutory conditions for the claim are met.
- Dependency determinations for a very young child are not limited to a rigid showing of a prior payment history, particularly where the child’s age and circumstances make such a history unrealistic; the question must be evaluated in light of the statute’s purpose and the facts.
- Summary judgment is improper where the law is applied as a blanket disqualification and where material questions remain concerning eligibility, including proof related to parentage and dependency.

## Conclusion

Heather v. Delta Drilling Company holds that Wyoming workers’ compensation death benefits cannot be denied by an automatic rule excluding illegitimate children; instead, an illegitimate child must be allowed to pursue benefits by establishing the necessary relationship and qualifying conditions, and the trial court’s summary judgment denying the claim was reversed and remanded for further proceedings.


Heather v. Delta Drilling Company, 533 P.2d 1211 (1975)