Boyd B. Hedleston v. Virginia Retirement System
62 Va. App. 592
| Va. Ct. App. | 2013Background
- Boyd B. Hedleston, a VRS member since 2007 and former high-school teacher, applied for disability retirement in May 2010 based primarily on cognitive deficits (short‑term memory loss) following a 2006 stroke.
- The Virginia Retirement System (VRS) Medical Board reviewed medical records and appellant testimony three times and recommended denial under Code § 51.1‑156(E), finding no objective proof of deterioration after VRS membership and that impairments could be explained by treatable anxiety/depression.
- An independent fact finder heard Hedleston’s testimony, reviewed Dr. Michael Fielding’s psychological report and other records, and found the evidence mixed and insufficiently corroborative to overturn the Medical Board.
- VRS issued a final denial; Hedleston appealed to the circuit court, which upheld VRS as supported by substantial evidence.
- On appeal to the Court of Appeals of Virginia, the panel reviewed the agency record under the Administrative Process Act standard (substantial evidence) and affirmed VRS’s denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether substantial evidence supported VRS’s denial of disability retirement under Code § 51.1‑156(E) | Hedleston: medical/psych reports and testimony show cognitive incapacity, permanence, and worsening since joining VRS | VRS: medical board and fact finder found no objective documentation of deterioration after membership and alternative explanations for deficits | Held: Yes — substantial evidence supports denial; requirements of incapacity, permanence, and substantial worsening not met |
| Whether pre‑existing condition bars retirement absent proof of substantial worsening | Hedleston: stroke‑related deficits justify retirement despite pre‑dating membership | VRS: statute requires convincing medical evidence of substantial worsening of pre‑existing condition | Held: Court agreed with VRS that Hedleston failed to show substantial worsening |
| Whether the court could reweigh medical evidence on review | Hedleston: agency misapplied medical evidence; court should overturn | VRS: APA restricts court to assessing substantial evidence; deference due to agency medical fact‑finding | Held: Court may not reweigh; must defer if reasonable minds could accept agency’s conclusion |
| Adequacy of psychological evaluation (Dr. Fielding) to establish disability | Hedleston: Dr. Fielding’s testing showed significant working‑memory deficits supporting incapacity | VRS: report showed mixed cognitive profile and other treatable causes; not dispositive or sufficiently corroborative | Held: Report was insufficiently conclusive; agency reasonably discounted it in denying benefits |
Key Cases Cited
- R.G. Moore Bldg. Corp. v. Mullins, 10 Va. App. 211, 390 S.E.2d 788 (Va. Ct. App. 1990) (view facts in the light most favorable to the prevailing party below)
- Virginia Real Estate Comm’n v. Bias, 226 Va. 264, 308 S.E.2d 123 (Va. 1983) (defines substantial evidence standard for agency findings)
- Johnston‑Willis, Ltd. v. Kenley, 6 Va. App. 231, 369 S.E.2d 1 (Va. Ct. App. 1988) (deference to agency expertise and presumption of regularity on review)
- Johnson v. Virginia Ret. Sys., 30 Va. App. 104, 515 S.E.2d 784 (Va. Ct. App. 1999) (role and authority of Medical Board in VRS disability determinations)
- Sandoval v. Commonwealth, 20 Va. App. 133, 455 S.E.2d 730 (Va. Ct. App. 1995) (credibility and weight of evidence are for the fact finder)
- Boone v. Harrison, 52 Va. App. 53, 660 S.E.2d 704 (Va. Ct. App. 2008) (court may not reweigh agency evidentiary record on review)
- Stancill v. Ford Motor Co., 15 Va. App. 54, 421 S.E.2d 872 (Va. Ct. App. 1992) (courts should avoid substituting their judgment for conflicting medical opinions)