A. Mahaffey v. WCAB (3B Pain Management Center, PC), A. Mahaffey v. WCAB (3B Pain Management Center, PC)

Claimant Anna Mahaffey, a massage therapist, filed a Claim Petition asserting work-related injuries to her hands (trigger fingers) and sought workers’ compensation benefits.
The WCJ found Claimant’s symptom testimony credible but rejected the medical testimony of Claimant’s expert physicians as not establishing causal connection to employment.
Employer’s medical experts (including a hand/upper-extremity specialist) were credited; the WCJ found their opinions persuasive that the trigger fingers were not caused by Claimant’s work and noted possible symptom magnification.
The WCJ noted that several of Claimant’s treating/examining physicians were seen after referral by Claimant’s attorney and questioned their credibility relative to Employer’s specialists and objective evidence.
The Board affirmed the WCJ’s decision, and Claimant appealed, arguing the WCJ failed to provide a reasoned decision and exhibited bias by repeatedly highlighting attorney referrals while not noting that Employer’s experts were retained for litigation.
The Commonwealth Court reviewed whether the WCJ’s findings were supported by substantial evidence and whether the WCJ satisfied the Section 422(a) reasoned-decision requirement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether WCJ issued a reasoned decision per Section 422(a)	Mahaffey: WCJ’s repeated references to attorney referrals and failure to note Employer experts were retained shows bias and insufficient reasoning	Employer: WCJ adequately explained credibility choices and relied on record evidence, including specialists’ credentials and objective findings	WCJ satisfied Section 422(a); decision was reasoned and reviewable
Whether Claimant proved work-related causal connection	Mahaffey: Medical testimony and her credible symptom testimony establish causation	Employer: Employer experts' testimony and objective findings defeat causal link; symptom magnification noted	Claimant failed to meet burden; causal link not established
Whether referral-by-attorney remarks rendered experts’ testimony unworthy of credit	Mahaffey: Emphasizing referrals improperly prejudiced Claimant’s experts	Employer: Court may consider circumstances of doctor–patient relationship and examination context when weighing credibility	Court held such consideration permissible; not arbitrary or capricious
Whether treating/examining physician testimony is presumptively superior	Mahaffey: Treating physicians should get greater credence	Employer: No automatic presumption; weight depends on ongoing treating relationship and quality of evidence	Court: No automatic greater weight; WCJ correctly evaluated relationship and evidence

Daniels v. Workers’ Compensation Appeal Board, 828 A.2d 1043 (Pa. 2003) (Section 422(a) requires articulation of objective basis for credibility determinations)
Dorsey v. Workers’ Compensation Appeal Board, 893 A.2d 191 (Pa. Cmwlth. 2006) (reasoned decision requirement and appellate review scope)
Inglis House v. Workmen’s Compensation Appeal Board, 634 A.2d 592 (Pa. 1993) (claimant bears burden to show injury in course of employment caused loss)
Amandeo v. Workers’ Compensation Appeal Board, 37 A.3d 72 (Pa. Cmwlth. 2012) (WCJ must review record and give objective rationale for accepting/rejecting evidence)
Sloane v. Workers’ Compensation Appeal Board, 124 A.3d 778 (Pa. Cmwlth. 2015) (distinguishing litigation-driven examinations from an ongoing treating relationship when assigning weight)