This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- The Worker, while employed at Aramark Services/Los Alamos National Laboratory, sustained injuries to her right knee after falling from a loading dock during the unloading of a delivery truck on June 18, 2013. The parties agreed that the Worker suffered compensable injuries to her left knee, cervical spine, and lumbar spine due to the work-related accident, leaving the compensation for the Worker’s right knee as the sole issue (para 2).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Worker-Appellant: Contended that the Workers Compensation Judge (WCJ) erred by rejecting expert testimony from her treating physicians and applied an incorrect legal standard in denying benefits for her right knee injury (para 1).
- Employer/Insurer-Appellees: Argued that the Worker’s right knee complaints were not causally related to the workplace accident to a reasonable degree of medical probability and that the Worker did not require further medical treatment for the contusion injury to her right knee beyond September 18, 2013 (paras 3-4).
Legal Issues
- Whether the WCJ erred in finding that the expert testimony regarding the Worker’s right knee pain and the work-related accident was insufficient to establish causation.
- Whether the WCJ abused its discretion in sustaining objections during the testimony of the Worker’s treating physicians on causation.
- Whether the WCJ applied an incorrect legal standard in determining the Worker failed to meet her burden of proof as to causation and in denying the Worker partial loss of use and medical benefits for her right knee injury.
Disposition
- The Court of Appeals affirmed the WCJ’s order denying benefits for injuries sustained by the Worker to her right knee (para 26).
Reasons
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The Court of Appeals, per Judge Medina, with Chief Judge Hanisee and Judge Zamora concurring, found that the WCJ did not err in its findings regarding the expert testimony of Dr. Garcia and Dr. Shields. The court held that Dr. Garcia’s testimony was vague and equivocal and did not sufficiently establish a causal connection between the accident and the Worker’s right knee complaints. The court also agreed with the WCJ that Dr. Shields lacked the requisite familiarity with the circumstances surrounding the Worker’s right knee complaints to form an informed opinion regarding causation. The court concluded that the WCJ applied the correct legal standard in determining that the Worker did not meet her burden of proof as to causation, affirming the WCJ’s conclusion that the Worker did not present expert testimony demonstrating a causal connection between the accident and the Worker’s right knee complaints sufficient to prove a disability or permanent impairment to the Worker’s right knee (paras 9-25).
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