## Facts

- Arthur Matthews worked loading heavy pulpwood onto trucks, involving repeated bending and straightening.
- On November 13, 1967, after several hours of loading, Matthews developed back pain that worsened and became disabling; he later underwent surgery for a herniated disc.
- The Industrial Accident Commissioner found Matthews’s herniated disc developed before November 13, 1967, and that no discrete work “accident” occurred that day.
- On May 1, 1969, the Commissioner entered a decree denying workers’ compensation; notice was received on May 13, 1969.
- Matthews sought Superior Court review by filing a Maine Rule of Civil Procedure 80B complaint and attaching an attested copy of the Commissioner’s decree.
- The employer and insurer moved to dismiss as procedurally improper; the Superior Court treated the filing as a statutory “presentation” under 39 M.R.S.A. § 103, denied dismissal, entered a pro forma decree, and the parties appealed.

## Issues

1. Whether Matthews’s Rule 80B complaint, filed within 20 days after notice and accompanied by an attested copy of the Commissioner’s decree, satisfied 39 M.R.S.A. § 103’s requirement that the decree be “certified and presented” to the court within 20 days, permitting entry of a pro forma decree and appeal.
2. If the appeal was valid, whether the Commissioner’s findings supporting denial of compensation were reversible under the applicable standard of review.

## Decision

- The Law Court held Matthews’s filing could be treated as a sufficient statutory “presentation” of the decree under 39 M.R.S.A. § 103, so the Superior Court properly denied the motion to dismiss and entered a pro forma decree.
- On the merits, the Law Court affirmed the denial of compensation, concluding the Commissioner’s findings were not clearly erroneous.

## Legal Principles

- Under 39 M.R.S.A. § 103, an appeal requires timely presentation to the Superior Court of a certified copy of the Commission decree (and related papers) within 20 days after notice, followed by entry of a pro forma decree and an appeal from that pro forma decree.
- The pro forma decree both makes the administrative decree enforceable and provides the procedural basis for appellate review.
- A miscaptioned or procedurally irregular filing may be accepted as a valid “presentation” when it functionally satisfies § 103’s timing and submission requirements.
- Findings of fact by the Industrial Accident Commissioner are reviewed under M.R.C.P. 52(a) and will not be set aside unless clearly erroneous; appellate review is especially limited when findings rest substantially on live testimony.

## Conclusion

The court preserved appellate jurisdiction by treating a timely Rule 80B complaint with an attested decree as satisfying the statutory presentation requirement, then affirmed the denial of benefits because the Commissioner’s factual findings—rejecting a compensable work accident and attributing the disc condition to a preexisting development—were not clearly erroneous.


Matthews v. R.T. Allen & Sons, Inc., 266 A.2d 240 (Me. 1970)