Workers’ Compensation · Primary-source case analysis

King v. CompPartners: Workers’ Compensation Exclusivity Barred a Tort Suit Against a Utilization Reviewer

By Aneeta Mishra and Timothy Chan

Published April 22, 2026

King addresses whether an injured worker may sue a utilization-review physician in tort for consequences of abruptly stopping an approved medication.

Review denied continued medication

An injured worker alleged seizures after a utilization reviewer denied continued Klonopin without authorizing a taper or warning about withdrawal risks. He sued the reviewer and review company for professional negligence.

The alleged harm arose within the compensation bargain

Utilization review is a statutorily required process performed for the employer to decide medical necessity. The injury alleged was derivative of the industrial claim and of acts undertaken to administer compensation benefits.

Exclusivity extended to the reviewer

The reviewer acted in a role contemplated by the workers’ compensation scheme. Allegations that review was careless did not transform the dispute into conduct outside the normal risks of the benefit process.

Disposition

The Supreme Court held the tort claims preempted, while noting that the compensation system supplies procedures for challenging treatment denials. The court did not approve abrupt cessation as sound medical practice.

Key takeaways

• Route utilization-review disputes through the statutory review process.
• Separate criticism of a medical decision from the forum authorized to remedy it.
• Exclusivity can protect participants acting on the employer’s behalf.
• Preserve treatment requests, review decisions, and time-sensitive appeals.