## Facts

- Danny Varney, a coal miner, became totally disabled by pneumoconiosis on March 5, 1988, and received workers’ compensation disability benefits apportioned between his employer and the Special Fund.
- At the time his compensable disability began, Varney was married to Ardena Varney and listed dependent children from that household in his claim.
- Samantha Danielle Varney was born on December 29, 1993, to Danny Varney and Tressa Sue Brewster.
- Varney married Brewster in January 1994 and divorced her in July 1995.
- Varney died from pneumoconiosis on December 10, 1996.
- In January 1997, Samantha’s mother moved to reopen Varney’s claim to seek workers’ compensation death benefits for Samantha as a dependent child.

## Issues

1. Whether KRS 342.316(7) bars occupational-disease death benefits for an after-born child whose relationship to the worker arose after the worker’s first compensable disability and who was not born of a marriage existing when that disability began.
2. Whether limiting death benefits to “after-born children of a marriage existing at the beginning” of the worker’s disability violates state or federal equal protection guarantees.

## Decision

- The Kentucky Supreme Court reversed the Court of Appeals and reinstated the denial of death benefits.
- The Court held that, under the plain text of KRS 342.316(7), Samantha was ineligible because she was born after the first compensable disability and was not an after-born child of the marriage that existed when the disability began.
- The Court held the statutory classification constitutional under rational-basis review because it was rationally related to legitimate state interests, including limiting beneficiaries and controlling system costs.

## Legal Principles

- In occupational-disease death claims, KRS 342.316(7) fixes eligibility by reference to the date of the worker’s “first compensable disability,” not the date of death.
- KRS 342.316(7) excludes death benefits for persons whose qualifying relationship to the worker arose after the first compensable disability, except for after-born children of a marriage that existed at the onset of that disability.
- Statutory line-drawing that limits workers’ compensation beneficiaries is reviewed under rational-basis scrutiny unless it creates a suspect classification or burdens a fundamental right.
- A classification tied to the family unit existing at the compensable event may be upheld where it reasonably serves administrative predictability and cost containment in the compensation system.

## Conclusion

The court enforced KRS 342.316(7) to deny occupational-disease death benefits to an after-born child who was not born of the worker’s marriage existing when the worker’s compensable disability began, and it upheld the statute against an equal protection challenge under rational-basis review.


Steven Lee Enters. v. Varney, 36 S.W.3d 391 (Ky. 2000)