Prior to 1949 the Department of Labor and Industries adjusted claims made under the Washington Industrial Insurance Act arising out of industrial injury, death, and disease, subject to review by the superior courts. Initial determinations were made ex parte by the Supervisor of Industrial Insurance. Appellate determinations, where a re-hearing was requested, were made by the Joint Board, consisting of the Director of the Department and two of his subordinates—the same Supervisor of Industrial Insurance who had made the initial determination, and the Supervisor of Safety. The Joint Board's primary function was quasi-judicial. However, since the tribunal consisted of the departmental officer whose order was the subject of the appeal, his administrative chief, and another subordinate of that chief, the procedure was aptly described as an example of the "defendant-judge" combination.
Donald H. Wollett,
The Board of Industrial Insurance Appeals After Nine Years: A Partial Evaluation,
33 Wash. L. Rev. & St. B.J.
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