A.E. Paris Contracting Company, Inc. and Zurich American Ins. Co. v. WCAB (Mace), A.E. Paris Contracting Company, Inc. and Zurich American Ins. Co. v. WCAB (Mace)

Claimant (injured 2012 at age 28) suffered a left-shoulder SLAP tear when ~400–500 lbs of gypsum fell on him while water-blasting; Employer paid benefits for Jan 6–Sep 1, 2012 then suspended benefits after Claimant returned to work without wage loss.
Claimant underwent 2012 surgery (Type 2 SLAP repair) by Dr. DeMeo, returned to work in modified duties, and continued to have shoulder pain that limited farm activities.
In 2013 Claimant had three nonwork falls (Jan) and a sudden worsening in Aug/Sep while sliding a computer chair at home; Dr. DeMeo diagnosed recurrent/frayed labrum (Type 1) and performed a second surgery on Oct 1, 2013.
Claimant petitioned to reinstate compensation (alleging the 2012 work injury worsened as of Sept 6, 2013); WCJ credited Claimant and Dr. DeMeo and ordered benefits from Sept 6, 2013 to May 28, 2014 (return-to-work date).
Employer’s IME (Dr. DiTano) opined the 2013 pathology was degenerative or caused/accelerated by the 2013 falls, not the 2012 work injury; WCJ rejected Dr. DiTano and found Dr. DeMeo’s opinion — that the 2012 repair left Claimant at greater risk of recurrent labral damage — sufficient to connect the 2013 surgery to the original work injury.
The Board affirmed; this Court affirmed, holding (1) claimant met burden to reinstate benefits and (2) the WCJ issued a reasoned decision addressing the material conflicts.

Issue	Claimant's Argument	Employer's Argument	Held
Whether claimant produced competent medical evidence tying the 2013 shoulder surgery to the 2012 work injury (reinstatement of benefits)	Dr. DeMeo: initial repair left the labrum weakened and "more likely than not" caused increased risk of recurrence, so the 2013 tear is causally related to the 2012 injury	Dr. DiTano: 2013 Type 1 fraying is degenerative or caused/accelerated by 2013 nonwork falls; Dr. DeMeo’s testimony was equivocal	Court held Dr. DeMeo’s testimony, viewed in full, was not equivocal; substantial competent evidence supported causation and reinstatement for a closed period (9/6/13–5/28/14)
Whether the WCJ’s decision satisfied Section 422(a) (reasoned decision) given inconsistencies in testimony (sliding vs. picking up chair; return-to-work restrictions)	Credited claimant’s consistent testimony and lack of malingering; inconsistencies immaterial to causation	WCJ failed to address inconsistencies; decision not reasoned	Court held WCJ adequately explained credibility findings, resolved material conflicts, and was not required to discuss every minor inconsistency; Section 422(a) satisfied

Soja v. Workers’ Compensation Appeal Board (Hillis‑Carnes Eng’g Assocs.), 33 A.3d 702 (Pa. Cmwlth. 2011) (standards for reinstatement of benefits after suspension)
Hinton v. Workers’ Compensation Appeal Board (City of Philadelphia), 787 A.2d 453 (Pa. Cmwlth. 2001) (presumption that work injury has not fully resolved after suspension)
City of Philadelphia v. Workers’ Compensation Appeal Board (McGinn), 879 A.2d 838 (Pa. Cmwlth. 2005) (when reinstating, claimant need not always produce causation evidence if presumption applies; but must show earning power adversely affected and same disability)
Riley Welding & Fabricating, Inc. v. Workers’ Compensation Appeal Board (DeGroft), 608 A.2d 598 (Pa. Cmwlth. 1992) (claimant must show the same disability for which benefits were initially paid)
Deitrich v. Workmen’s Compensation Appeal Board (Shamokin Cycle Shop), 584 A.2d 372 (Pa. Cmwlth. 1990) (language like "most likely" or "probably" does not automatically render a medical opinion equivocal)
Philadelphia Coll. of Osteopathic Med. v. Workmen’s Compensation Appeal Board (Lucas), 465 A.2d 132 (Pa. Cmwlth. 1983) (medical opinion stating belief/opinion is competent evidence despite expressed uncertainty)
Degraw v. Workers’ Compensation Appeal Board (Redner’s Warehouse Markets, Inc.), 926 A.2d 997 (Pa. Cmwlth. 2007) (medical opinion is incompetent only if based solely on inaccurate or false information; gaps go to weight, not competency)