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CourtListener opinion 10783480

Date unknown · US

Extracted case name
pending
Extracted reporter citation
552 P.3d 235
Docket / number
20230789-CA
QDRO relevance 5/5Retirement relevance 5/5Family-law relevance 5/5gold label pending
Research-use warning: This page contains machine-draft public annotations generated from public opinion text. The headnote is not Willie-approved gold-label work product and is not legal advice. Verify the full opinion and current law before relying on it.

Machine-draft headnote

Machine-draft public headnote: CourtListener opinion 10783480 is included in the LexyCorpus QDRO sample set as a public CourtListener opinion with relevance to QDRO procedure / domestic relations order issues. The current annotation is conservative: it identifies source provenance, relevance signals, and evidence quotes for attorney/agent retrieval. It is not a Willie-approved legal headnote yet.

Retrieval annotation

Draft retrieval summary: this opinion has QDRO relevance score 5/5, retirement-division score 5/5, and family-law score 5/5. Use the quoted text and full opinion below before relying on the case.

Category: QDRO procedure / domestic relations order issues

Evidence quotes

QDRO

he district court should use the "Woodward formula" to determine how to divide their retirement accounts, and in the final divorce decree, the court ordered that this is how the accounts should be divided. Id. ¶ 4. But when the husband's attorney prepared the qualified domestic relations order (the QDRO) 9 and sent it to the wife's attorney, it became clear that the parties had very different ideas about what that formula entailed and how it would actually be applied to the accounts in question. See id. ¶¶ 5–8. The wife accordingly filed both an objection to the QDRO and a rule 60(b) motion, asking the district court to set aside the divorce decr

retirement benefits

hat it could. Our decision in Granger v. Granger, 2016 UT App 117, 374 P.3d 1043, is perhaps the clearest example. There, the parties in a divorce action had stipulated that the district court should use the "Woodward formula" to determine how to divide their retirement accounts, and in the final divorce decree, the court ordered that this is how the accounts should be divided. Id. ¶ 4. But when the husband's attorney prepared the qualified domestic relations order (the QDRO) 9 and sent it to the wife's attorney, it became clear that the parties had very different ideas about what that formula entailed and how it would actually be

domestic relations order

t court should use the "Woodward formula" to determine how to divide their retirement accounts, and in the final divorce decree, the court ordered that this is how the accounts should be divided. Id. ¶ 4. But when the husband's attorney prepared the qualified domestic relations order (the QDRO) 9 and sent it to the wife's attorney, it became clear that the parties had very different ideas about what that formula entailed and how it would actually be applied to the accounts in question. See id. ¶¶ 5–8. The wife accordingly filed both an objection to the QDRO and a rule 60(b) motion, asking the district court to set aside the divorce decr

Source and provenance

Source type
courtlistener_qdro_opinion_full_text
Permissions posture
public
Generated status
machine draft public v0
Review status
gold label pending
Jurisdiction metadata
US
Deterministic extraction
reporter: 552 P.3d 235 · docket: 20230789-CA
Generated at
May 14, 2026

Related public corpus pages

Deterministic links based on shared title/citation terms and QDRO / retirement / family-law retrieval scores.

Clean opinion text

2025 UT App 7

 THE UTAH COURT OF APPEALS

 WAXIES ENTERPRISES INC. AND
 AMERICAN ZURICH INSURANCE CO.,
 Petitioners,
 v.
 THOMAS J. HALLADAY AND LABOR COMMISSION,
 Respondents.

 Opinion
 No. 20230789-CA
 Filed January 16, 2025

 Original Proceeding in this Court

 Bret A. Gardner and Kristy L. Bertelsen,
 Attorneys for Petitioners
 Jay K. Barnes and Virginius Dabney,
 Attorneys for Respondent Thomas J. Halladay

JUDGE RYAN D. TENNEY authored this Opinion, in which JUDGES
 MICHELE M. CHRISTIANSEN FORSTER and DAVID N. MORTENSEN
 concurred.

TENNEY, Judge:

¶1 Thomas Halladay was injured when he fell off a ladder
while working for Waxies Enterprises (Waxies). Halladay filed a
claim with the Labor Commission seeking compensation for his
injuries, and the parties later reached a settlement agreement.
After the parties had signed the agreement and the Labor
Commission approved it, however, Waxies and Halladay learned
that they had divergent ideas about how to interpret one of its
material terms. When Waxies asked Halladay to sign certain
documents that would effectively decide the question in its favor,
Halladay refused.
 Waxies Enterprises v. Labor Commission

¶2 Waxies then filed a motion asking the Labor Commission
to compel Halladay to sign the requested documents. In the
alternative, Waxies asked the Labor Commission to set aside its
prior approval of the settlement agreement. The Labor
Commission denied both requests.

¶3 Waxies now seeks judicial review. For the reasons set forth
below, we decline to disturb the Labor Commission's decision on
the motion to compel, but we vacate its denial of the motion to set
aside its approval of the settlement agreement.

 BACKGROUND

¶4 In November 2012, Halladay was working for Waxies
when the ladder that he was standing on slid out from under him,
causing him to fall and sustain injuries to his spine and the left
side of his body. In late 2020, Halladay brought a claim against
Waxies seeking an award of disability benefits. 1 The parties
litigated the matter, and an administrative law judge (ALJ) found
that causation had been established and awarded permanent total
disability benefits to Halladay. The Labor Commission's Appeals
Board (the Appeals Board) affirmed that decision.

¶5 Waxies sought review from this court, but the parties were
directed to mediation. During that subsequent mediation, the
parties agreed to the terms of a settlement agreement (the

1. American Zurich Insurance Co. was Waxies' insurance
provider and is a named party. Waxies and American Zurich have
litigated together throughout this case. For simplicity, we'll refer
to them collectively as Waxies throughout this opinion.

 20230789-CA 2 2025 UT App 7
 Waxies Enterprises v. Labor Commission

Settlement Agreement), and the Labor Commission, through an
ALJ, approved it two months later. 2

¶6 The Settlement Agreement primarily consisted of two
parts. First, Waxies agreed to pay Halladay a lump sum of
$250,000, which represented "ongoing indemnity benefits" for
Halladay because of his limited "ability to engage in substantial,
gainful employment [going] forward." Second, Waxies agreed to
provide a "Medicare Set-aside Allocation" (MSA) to cover
Halladay's future medical expenses. The form and function of this
MSA was laid out in the Settlement Agreement as follows:

 • "[Waxies] will pay to [Halladay] the total of $166,246.47 . . .
 for future medical expenses related to the November 5,
 2012 work accident . . . ."

 • "It is further agreed by the parties that the MSA . . . of
 $166,246.47 will be paid to [Halladay] in the form of a
 structure[d] annuity. An initial MSA seed payment of
 $23,183.00 will be paid to [Halladay] by not later than 30
 days from the date that the Utah Labor Commission
 approves this Settlement Agreement. Thereafter, annual
 annuity payments will be made to [Halladay] of $10,218.00
 on the anniversary date of the initial payment and shall
 continue to be paid each year thereafter on or about the
 anniversary date and each anniversary date thereafter so
 long as [Halladay] lives."

 • "The MSA of $166,246.47 is not guaranteed to be paid to
 [Halladay] in its entirety, and shall be paid to [Halladay] so

2. As will be discussed in more detail below, an ALJ has statutory
authority to approve settlement agreements on behalf of the
Labor Commission in workers' compensation cases. See Utah
Code § 34A-2-420(4).

 20230789-CA 3 2025 UT App 7
 Waxies Enterprises v. Labor Commission

 long as [Halladay] lives. No MSA annuity payments will
 be made after [Halladay's] date of death."

 • "[Halladay] elects to have the MSA professionally
 administered for him by [third parties]." 3

¶7 According to Waxies' subsequent account, "within a few
hours" after the Labor Commission approved the Settlement
Agreement, Waxies asked Halladay, for the first time, to sign two
additional documents. One was titled the "Terms of Structured
Settlement with Assignment" (the TSSA), and the other was titled
the "Qualified Assignment and Release Agreement" (the QARA).
Both of these documents contained language assigning Waxies'
obligations to make the annual MSA payments to a third party.
Moving forward, we'll refer to the two documents together as the
Assignment Documents.

¶8 Of note, the TSSA described the MSA payments as
"beginning 4/1/2024, paid for 14 years, only if . . . Halladay is
living when the payment is due." And the QARA likewise
described the MSA as a "Temporary Life Annuity" with periodic
payments made "for a maximum of 14 year(s)."

¶9 After reviewing these documents, Halladay refused to sign
them. And in discussions between the two sides' attorneys, it
became clear that the two sides had differing ideas about whether
these documents accurately reflected the nature of the Settlement

3. As noted, in this provision, Halladay agreed to have the MSA
professionally administered by third parties. The Settlement
Agreement did reference Halladay signing one document, a
"Certified MSA Self Administration Support Service Agreement,"
and Halladay signed that document without incident. But this
provision did not reference the assignment of the MSA, nor did it
mention any other forms that might be necessary to carry out the
third-party administration.

 20230789-CA 4 2025 UT App 7
 Waxies Enterprises v. Labor Commission

Agreement itself. In Waxies' view, because the Settlement
Agreement said that Waxies would pay a "total" amount of
$166,246.47 for "future medical expenses," with those medical
expenses being paid to Halladay through the MSA, and because
the Settlement Agreement also said that Halladay would receive
an initial payment of $23,183.00 followed by annual annuity
payments of $10,218.00, this meant that Waxies' obligations
would end after 14 years. 4

¶10 In Halladay's view, however, what mattered was that the
Settlement Agreement specifically provided for "annual annuity
payments" of $10,218.00 "so long as [Halladay] live[d]." 5 Because
the Assignment Documents explicitly limited the overall MSA
obligations to 14 years of payments, Halladay believed that they
made "significant changes" to the Settlement Agreement's
substantive terms. It was for this reason that, on the advice of
counsel, he refused to sign them.

¶11 On May 9, 2023, Waxies filed a motion asking the Labor
Commission to compel Halladay to sign the Assignment
Documents. In this motion, Waxies argued that the Assignment
Documents were necessary for the structured annuity to be
funded and professionally administered. Because Halladay had
agreed to have the MSA professionally administered by a third
party, Waxies asked the Labor Commission to order him to sign

4. The actual total arrived at by adding $143,052.00 (14 times
$10,218.00) to $23,183.00 is $166,235.00, not $166,246.47. Neither
party mentions this minor discrepancy in their briefing, so we
have no need to comment on it further.

5. In his brief to this court, Halladay accounted for the language
limiting Waxies' obligations to $166,246.47 by suggesting that
Waxies' obligations to make payments to the MSA were limited to
that amount, and that it then had an obligation to make payments
directly to him "for the remainder of his life."

 20230789-CA 5 2025 UT App 7
 Waxies Enterprises v. Labor Commission

those documents. In an alternatively filed motion to set aside,
Waxies argued that, in the event that the Labor Commission
refused to order Halladay to sign the Assignment Documents, the
Labor Commission should set aside the Settlement Agreement
entirely. In Waxies' view, the parties' disagreement about the
scope of Waxies' obligations to pay Halladay's medical expenses
showed that they had not agreed on "a material term" of how to
settle Halladay's claims. And because the $250,000 payment was
part of that same settlement, Waxies also asked the Labor
Commission to order him to return those funds.

¶12 Halladay opposed these motions on several grounds. Of
note here, with respect to the motion to compel, Halladay argued
that the motion related to the enforcement of the Settlement
Agreement but that the Labor Commission lacked jurisdiction to
take any enforcement action. 6 And with respect to the motion to
set aside, Halladay asked the Labor Commission to deny the
motion because, in his view, the Settlement Agreement
unambiguously "require[d] that yearly payments be made to . . .
Halladay for life."

¶13 The same ALJ that had previously approved the Settlement
Agreement denied both motions. With respect to the motion to
compel, the ALJ concluded that it "lack[ed] jurisdiction to compel
any party to sign a settlement agreement or any document
related" to the Settlement Agreement. With respect to the motion
to set aside the Settlement Agreement, the ALJ concluded that
"the parties [had] reached an agreement" that had previously
been approved, the "terms within the agreement [were] clear,"
and there was "nothing contained within the agreement which
would warrant setting the agreement aside." While the ALJ

6. Halladay did indicate, however, that he would be willing to
sign documents relating to an assignment if the documents were
changed to reflect his view of Waxies' obligations relating to his
medical expenses.

 20230789-CA 6 2025 UT App 7
 Waxies Enterprises v. Labor Commission

opined that the terms were "clear," it did not indicate whether it
agreed with Waxies or instead Halladay on the key point of
contention.

¶14 Waxies requested review from the Appeals Board, and the
Appeals Board subsequently issued a decision affirming both
aspects of the ALJ's order. First, on the motion to compel, the
Appeals Board concluded that "[w]hile the [Labor] Commission's
applicable statutes and rules permit settlement agreements, there
is no corresponding language that would authorize the [Labor]
Commission or the Appeals Board to compel a party to submit to
terms of such an agreement." Second, on the motion to set aside,
the Appeals Board concluded there had "been no cause shown for
the Appeals Board to rescind or revisit its prior order" approving
the Settlement Agreement. The Appeals Board acknowledged the
"apparent gap" in the parties' positions on how long Waxies was
required to make payments for the MSA, but the Appeals Board
concluded that this did "not necessarily translate to nullification
of the" Settlement Agreement. Instead, it concluded that it had
"no authority to reform the parties' settlement agreement or to set
it aside" and that it had "no role in dictating the type of financial
instruments used by Waxies to fund its obligations."

 ISSUES AND STANDARD OF REVIEW

¶15 Waxies seeks judicial review of the Appeals Board's
decision to affirm the ALJ's denial of Waxies' motion to compel
Halladay's signature on the Assignment Documents or,
alternatively, to set aside the Settlement Agreement. "Both of
these issues present questions of statutory interpretation, and the
[Labor] Commission's interpretation of a statute is a question of
law, which we review for correctness." Mayhew v. Labor Comm'n,
2024 UT App 81, ¶ 33, 552 P.3d 235 (quotation simplified), cert.
denied, 554 P.3d 1097 (Utah 2024).

 20230789-CA 7 2025 UT App 7
 Waxies Enterprises v. Labor Commission

 ANALYSIS

 I. Motion to Compel

¶16 Under the Workers' Compensation Act, a Labor
Commission "administrative law judge shall review and may
approve the agreement of the parties to enter into a full and final
settlement." Utah Code § 34A-2-420(4). If a settlement agreement
is approved, it becomes "the final order of the commission" unless
a party appeals to the Labor Commission's Division of
Adjudication. Id. § 34A-1-303(1); see also id. § 34A-1-102(2) (stating
that references to the "Commission" in title 34A refer to "the
Labor Commission"). As noted, an ALJ (and, by extension, the
Labor Commission) approved the Settlement Agreement that's at
the center of this case.

¶17 The first issue before us is whether the Labor Commission
had authority to later compel Halladay to sign certain documents
relating to the assignment of Waxies' obligations with respect to
the MSA. The Labor Commission concluded that this request
amounted to an enforcement action but that it lacked authority to
enforce settlement agreements. We agree.

¶18 The Workers' Compensation Act specifies—under the
heading of "Enforcing judgment"—that "an abstract of a final
order of the [Labor Commission] providing an award may be filed
. . . in the office of the clerk of the district court of any county in
the state," and it then states that the "district court may issue an
execution or a renewal on the order within the same time and in
the same manner and with the same effect as if the order were a
judgment issued by the district court." Id. § 34A-2-212(1)(a), (d).
This statute creates the "mechanism" by which a party can "use
the district court to enforce the payment of an award issued by
the [Labor] Commission by filing an abstract of any final order
providing an award with the district court." Thomas v. Color
Country Mgmt., 2004 UT 12, ¶ 10, 84 P.3d 1201 (quotation

 20230789-CA 8 2025 UT App 7
 Waxies Enterprises v. Labor Commission

simplified); id. (citing Utah Code section 34A-2-212(1)(a) as the
appropriate means of enforcing a temporary disability award
when a final order has been made). Moreover, Utah Code section
63G-4-501 creates additional means by which an administrative
agency's orders can be enforced, and those mechanisms likewise
call for "civil enforcement" of agency orders through the district
courts.

¶19 Waxies points to no authority, and we have found none,
that gives the Labor Commission authority to enforce settlement
agreements itself. Instead, the relevant statutes suggest that
enforcement actions are the province of the district courts. As a
result, if Waxies is correct that the settlement requires Halladay to
sign the Assignment Documents in order to effectuate the terms
of the Settlement Agreement, Waxies must seek relief in the
district courts. But because Waxies has not shown that the Labor
Commission had authority to compel Halladay to sign the
Assignment Documents as an exercise of enforcement power, we
decline to disturb the Labor Commission's denial of Waxies'
motion to compel. 7

7. In its brief and again at oral argument, Waxies alternatively
suggested that this court "has jurisdiction" itself "to enforce and
compel execution" of the Settlement Agreement by ordering
Halladay to sign the Assignment Documents. But Waxies
provided no explanation or authority for its suggestion that this
court can or should order this in the first instance. Waxies
therefore has not carried its burden of persuasion, so we reject the
request. See State v. Draper, 2024 UT App 152, ¶ 74, -- P.3d --
("Under the Utah Rules of Appellate Procedure, a party must
provide this court with an argument that explains, with reasoned
analysis supported by citations to legal authority and the record,
why the party should prevail on appeal. These requirements are
a natural extension of an appellant's burden of persuasion."
(quotation simplified)).

 20230789-CA 9 2025 UT App 7
 Waxies Enterprises v. Labor Commission

 II. Motion to Set Aside

¶20 Waxies next argues that the Labor Commission (through
the Appeals Board) erred by not granting the motion to set aside.
In Waxies' view, the Labor Commission should have granted the
motion once it became apparent that there had not been a meeting
of the minds about how long Waxies was required to make MSA
payments. Though a touch unclear, the Appeals Board seems to
have concluded that it lacked authority to set aside the approval
of the settlement on this basis. We disagree, so we accordingly set
aside that decision.

¶21 By statute, "an administrative law judge shall review and
may approve the agreement of the parties to enter into a full and
final settlement" in a workers' compensation case, Utah Code
§ 34A-2-420(4), and the Utah Administrative Code sets forth
procedures for the approval (or non-approval) of such
agreements, see Utah Admin. Code R602-6-1 to -4. If an ALJ
approves a settlement, that approval is "the final order of the
commission" unless a party appeals. Utah Code § 34A-1-303(1). 8

¶22 As an initial matter, Waxies suggests in its brief that its
motion to set aside should be interpreted as "an appeal" "in the
form of" a motion to set aside. But by statute, a party who seeks
to "appeal the decision of an administrative law judge" must do

8. Waxies' motion asked the Labor Commission to set aside the
Settlement Agreement itself. But the Labor Commission's prior
role in this process was to issue an order approving that settlement.
See Utah Code § 34A-2-420(4); Utah Admin. Code R602-6-1 to -4.
That said, under Utah Code section 34A-2-108(1), without that
approval, the agreement by Halladay to waive his "rights to
compensation" would "not [be] valid." Thus, while we construe
Waxies' motion as being a motion to set aside the prior approval
of the Settlement Agreement, the ultimate effect would be the
same.

 20230789-CA 10 2025 UT App 7
 Waxies Enterprises v. Labor Commission

so "by filing a motion for review with the Division of
Adjudication within 30 days of the date the decision is issued." Id.
§ 34A-2-801(4)(a). The Settlement Agreement was approved on
April 5, 2023, but the motion to set aside was not filed until May
9, 2023, which is a gap of 34 days. If this motion was meant to be
an appeal, it was four days too late. Cf. Price v. Labor Comm'n, 2021
UT App 138, ¶ 23, 504 P.3d 723 (declaring a settlement agreement
approved by an administrative law judge as "final" when it was
not appealed to the Labor Commission within 30 days).

¶23 But Waxies also suggests that the motion was proper on its
own terms as a motion to set aside the prior approval. In Waxies'
view, the ALJ both could and should have granted the motion
through an exercise of the Labor Commission's "continuing
jurisdiction." As noted, the ALJ denied that request, and the
Appeals Board later upheld that denial. In the view of the Appeals
Board, there had "been no cause shown for the Appeals Board to
rescind or revisit its prior order."

¶24 We disagree with the Appeals Board on this point, and our
disagreement relates to the nature of the Labor Commission's
continuing jurisdiction. In Price v. Labor Commission, we explained
that the Labor Commission "retains continuing jurisdiction over
workers' compensation cases, and ‘may from time to time modify
or change a former finding or order,' even after the thirty-day
appeal window has passed." Id. ¶ 24 (quoting Utah Code § 34A-
2-420(1)(b)). And as an initial matter, we explained that this
continuing jurisdiction allows the Labor Commission to correct a
past order for "clerical or other errors in an administrative
decision," as well as in situations "where a claimant's medical
condition deviates from its anticipated course." Id. (quotation
simplified). Neither of those jurisdictional bases are at issue in this
case.

¶25 Relying on a previous case from our supreme court, we
further explained that the statutory "‘grant of continuing

 20230789-CA 11 2025 UT App 7
 Waxies Enterprises v. Labor Commission

jurisdiction' is broader than, but ‘encompasses, the authority that
district courts have under rule 60' of the Utah Rules of Civil
Procedure." Id. (quoting Frito-Lay v. Labor Comm'n, 2009 UT 71,
¶ 25, 222 P.3d 55). And in that case, our supreme court had noted
that "the power of the [Labor Commission] as to its continuing
jurisdiction is not limited to consideration of changes in physical
condition of workmen, but is extended to the right to rescind, alter,
or amend orders, decisions, or awards on good cause appearing
therefor." Frito-Lay, 2009 UT 71, ¶ 25 (emphasis added, quotation
otherwise simplified). Thus, while a challenge to the "propriety of
[a] final legal determination[] made by the [Labor] Commission .
. . must be brought through direct review and not by bringing
another action upon the same cause," the Labor Commission's
continuing jurisdiction does allow it to grant relief "for reasons
similar to those set forth in rule 60 of the Utah Rules of Civil
Procedure," Price, 2021 UT App 138, ¶ 25 (quotation simplified),
and this includes the authority to "rescind" past orders for "good
cause," Frito-Lay, 2009 UT 71, ¶ 25 (quotation simplified).

¶26 The procedural posture of this case is somewhat unusual
as far as rule 60 motions relating to a contract dispute might
ordinarily go. After all, if two parties to a contract have a
disagreement about its meaning, that disagreement can be
resolved through litigation, and a rule 60 motion would typically
be filed after the parties had litigated the question and the court
had thus analyzed and ruled on the contract's terms. Here,
however, the parties have not yet litigated the question of how to
interpret the Settlement Agreement. The role of the tribunal to this
point has simply been the Labor Commission's decision to
approve the agreement. But even so, rule 60 allows a party to
obtain relief "from a judgment, order, or proceeding." Utah R.
Civ. P. 60(b). We have no difficulty concluding that the approval
of the agreement would constitute an "order" here.

¶27 Given this, the question is whether rule 60, or even some
reason that is "similar" to reasons contemplated by rule 60, could

 20230789-CA 12 2025 UT App 7
 Waxies Enterprises v. Labor Commission

justify vacating a prior approval if it becomes clear that there was
not a meeting of the minds. Surveying the cases, we agree with
Waxies' contention that it could. Our decision in Granger v.
Granger, 2016 UT App 117, 374 P.3d 1043, is perhaps the clearest
example. There, the parties in a divorce action had stipulated that
the district court should use the "Woodward formula" to determine
how to divide their retirement accounts, and in the final divorce
decree, the court ordered that this is how the accounts should be
divided. Id. ¶ 4. But when the husband's attorney prepared the
qualified domestic relations order (the QDRO) 9 and sent it to the
wife's attorney, it became clear that the parties had very different
ideas about what that formula entailed and how it would actually
be applied to the accounts in question. See id. ¶¶ 5–8. The wife
accordingly filed both an objection to the QDRO and a rule 60(b)
motion, asking the district court to set aside the divorce decree in
light of the parties' now-apparent disagreement about what the
formula meant. See id. ¶¶ 6–7.

¶28 The district court denied the motion, but we reversed that
denial on appeal. See id. ¶¶ 14–27. We noted that it "is a basic
principle of contract law [that] there can be no contract without a
meeting of the minds." Id. ¶ 14 (quotation simplified). We then
held that although the wife had initially stipulated to a division of
the accounts pursuant to the Woodward formula, the district court
should have allowed her to set aside that stipulation once it
became clear that the parties had never actually agreed on "the
actual mathematical mechanism that would be used to divide" the
retirement accounts. Id. ¶ 22. We thus held that there had been
"no meeting of the minds" on this key point and that the ensuing
litigation had made it clear that neither the husband nor the wife

9. A QDRO is an order that "furnishes instructions to the trustee
of a retirement plan and specifies how distributions should be
made, to whom, and when." Granger v. Granger, 2016 UT App 117,
¶ 5 n.3, 374 P.3d 1043 (quotation simplified).

 20230789-CA 13 2025 UT App 7
 Waxies Enterprises v. Labor Commission

had "contemplated application of the Woodward formula in the
manner contemplated by the other." Id. ¶ 23. We accordingly
remanded for further proceedings. See id. ¶ 26.

¶29 Though not a contract case, our supreme court's decision
in In re Discipline of Rasmussen, 2013 UT 14, 299 P.3d 1050, is also
instructive. There, a district court had issued an order suspending
an attorney from practicing law. See id. ¶ 2. The attorney later filed
a request for reinstatement, but the Office of Professional Conduct
(OPC) filed a memorandum opposing that request. See id. ¶¶ 3–4.
In response, the attorney argued that OPC's opposition was not
timely filed, and the timeliness question he raised turned on how
to interpret the original suspension order. See id. ¶ 5. If it was read
one way, a particular rule applied and the opposition was timely
filed; but if it was read another way, a different rule applied and
it was not. See id. In considering the matter, the district court
opined that the terms of its own initial suspension order had been
"unclear," so the court accordingly allowed OPC to file the
opposition. See id. ¶ 6.

¶30 The case later reached the supreme court. There, the
supreme court held that OPC's opposition to the motion for
reinstatement "was effectively a rule 60(b) motion"—and, more
particularly, a motion under rule 60(b)(6), which allows for relief
"based on ‘any other reason justifying relief from the operation of
the judgment.'" Id. ¶ 12 (quoting Utah R. Civ. P. 60(b)). In the
supreme court's view, "the ambiguity in the suspension order
created confusion," and "that confusion meant that each party
was operating under a different set of expectations and a different
timeframe." Id. In light of that confusion, the supreme court held
that the district court's decision to allow OPC to file its opposition
"was entirely appropriate under rule 60(b)(6) given these unusual
circumstances." Id.

¶31 Applying these principles here, we conclude that when
Waxies asked the Labor Commission to set aside the prior

 20230789-CA 14 2025 UT App 7
 Waxies Enterprises v. Labor Commission

approval of the Settlement Agreement, it did so for "reasons
similar to those set forth in rule 60 of the Utah Rules of Civil
Procedure." Price, 2021 UT App 138, ¶ 25. Again, Waxies' motion
was based on its assertion that the parties never had a meeting of
the minds about how long Waxies must make the MSA payments.
And having reviewed the record and the parties' arguments, we
conclude the basis for this assertion is clear enough: in one place,
the Settlement Agreement states that Waxies is obligated to pay
"the total of $166,246.47" to fund the MSA, but in another, the
Settlement Agreement states that Waxies must pay an annual
annuity payment of $10,218.00 "so long as [Halladay] lives."
These provisions, as well as the parties' almost immediately
divergent interpretations of them, together raise a cognizable
claim of a failure of a meeting of the minds that should be
addressed by the Labor Commission in the first instance.

¶32 Moreover, we note that our supreme court has explained
that the Labor Commission's continuing jurisdiction should not
be "burden[ed] with technicalities," and it has further explained
that the Labor Commission's authority is intended to "empower
the [Labor] Commission to prevent inadequate or excessive
awards." Frito-Lay, 2009 UT 71, ¶ 28. But if it's true that there was
no meeting of the minds in this case on a key term or terms, then
the result could well be either an inadequate or an excessive
award: if Waxies is forced to pay a large amount that it did not
actually agree to pay, this would constitute an "excessive" award;
but if Waxies is allowed to avoid paying an amount that it actually
did agree to pay, the result would be an "inadequate" award. For
this reason too, resolution of this question seems to be well within
the nature of the Labor Commission's jurisdiction. See Granite
School Dist. v. Young, 2023 UT 21, ¶¶ 34, 37, 537 P.3d 225
(explaining that the Labor Commission has "exclusive
jurisdiction" "over the determination of the amount of a
compensation award" (quotation simplified)).

 20230789-CA 15 2025 UT App 7
 Waxies Enterprises v. Labor Commission

¶33 Given these circumstances, we conclude that the Labor
Commission had authority to rescind its prior approval of the
Settlement Agreement once it was presented with a substantial
question as to whether there had been a meeting of the minds on
this material term. Because the Appeals Board ruled that it lacked
such authority, we set aside that decision. 10

10. We note one lingering issue that we choose not to resolve.
Even with the continuing jurisdiction afforded to the Labor
Commission, our courts have also recognized that there's still a
"justified need for finality in administrative decisions." Merrill v.
Labor Comm'n, 2009 UT 74, ¶ 17, 223 P.3d 1099 (quotation
simplified); accord Price v. Labor Comm'n, 2021 UT App 138, ¶ 25,
504 P.3d 723. According to the supreme court, the Labor
Commission's exercise of its continuing jurisdiction must
accordingly be harmonized with principles such as "waiver and
finality," which "are most applicable to settled cases." Merrill,
2009 UT 74, ¶ 18. In Price, we thus cautioned that "challenges to
the propriety of final legal determinations made by the [Labor]
Commission (or by an administrative law judge) must be brought
through direct review and not by bringing another action upon
the same cause," and we further stressed that "simple invocation
of ‘continuing jurisdiction' is not sufficient to justify any late
challenge to all rulings rendered by the [Labor] Commission."
2021 UT App 138, ¶ 25 (quotation simplified).
 In his brief before this court, Halladay argued that, to the
extent that Waxies' motion to set aside was meant to be a request
for direct review, it was untimely. As noted, we're persuaded by
that argument. But we see no place (either below or on review)
where Halladay has meaningfully briefed the separate question
of whether the Labor Commission's exercise of its continuing
jurisdiction is subject to any time limits of its own. Nor, for that
matter, has Halladay meaningfully developed an argument that,
 (continued…)

 20230789-CA 16 2025 UT App 7
 Waxies Enterprises v. Labor Commission

 CONCLUSION

¶34 For the reasons set forth above, we decline to disturb the
Labor Commission's decision not to compel Halladay to sign the
Assignment Documents, but we set aside its decision that it had
no power to potentially rescind the prior approval of the
Settlement Agreement, and we instruct the Labor Commission to
revisit this issue.

because Waxies in theory could have filed a timely appeal from
the approval of the Settlement Agreement, its failure to do so
somehow foreclosed Waxies from instead asking the ALJ to set
aside the approval as an exercise of the Labor Commission's
continuing jurisdiction. We note that Waxies' brief sheds little
light on these questions as well.
 But these questions potentially implicate significant issues
about the limitations (if any) on the Labor Commission's ability to
exercise continuing jurisdiction in such circumstances. Without
meaningful briefing, we decline to weigh in on them, instead
leaving resolution of them for another case.

 20230789-CA 17 2025 UT App 7