Hart by and through Hart v. State ex rel. Department of Workforce Services, Workers' Compensation Division, 442 P.3d 653

In 2005 Pete Hart suffered a work-related back injury for which he received temporary disability and a 12% whole person impairment award (permanent partial) in 2006.
Hart continued working while receiving treatment (injections, pain meds) but stopped working after a July 2013 emergency event (swollen tongue, slurred speech). He never returned to work.
In October 2013 Hart was diagnosed with ALS. He applied for permanent total disability benefits in January 2014, claiming his back pain and need for pain medication (which his employer allegedly prohibited at work) prevented return.
The Division denied permanent total benefits after an independent exam by Dr. Kaplan concluded Hart’s inability to work stemmed from ALS, not the 2005 back injury. Hart objected and the matter went to the Medical Commission.
Hart and his treating physician (Dr. Bedell) died before the hearing; Mrs. Hart testified but lacked specifics about medication use and timing. The Medical Commission credited Dr. Kaplan over Dr. Bedell’s certification and Mrs. Hart’s general testimony and denied benefits.
The district court remanded the Commission’s initial order for more detailed findings; on remand the Commission issued a more detailed supplemental order reaching the same result. The district court then affirmed, and the Wyoming Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court should have reversed and awarded benefits instead of remanding for further findings	Hart: District court should have resolved deficiencies and awarded benefits without remand (citing Rodgers)	Division: Remand appropriate when agency record and findings are insufficient for review	Remand was proper; Rodgers was distinguishable and remand is the normal course when agency findings are incomplete
Whether Medical Commission’s denial (finding ALS, not work injury, caused inability to work) is supported by substantial evidence	Hart: Commission relied on speculative/inappropriate aspects of Dr. Kaplan and ignored evidence that back injury/medication policy prevented return to work	Division: Substantial evidence (Dr. Kaplan’s exam/deposition, medical records, lack of specificity in Mrs. Hart’s testimony, absence of ER records) supports denial	Affirmed: Commission’s conclusion that Hart failed to prove his inability to work was caused by the work-related back injury (record supports conclusion)

Decker v. State ex rel. Wyo. Med. Comm'n, 124 P.3d 686 (Wyo. 2005) (remand to agency appropriate when record or findings are insufficient for review)
Bush v. State ex rel. Wyo. Workers' Comp. Div., 120 P.3d 176 (Wyo. 2005) (disfavors de novo factfinding by courts reviewing agency credibility/weight determinations)
Rodgers v. State ex rel. Wyo. Workers' Safety & Comp. Div., 135 P.3d 568 (Wyo. 2006) (rare case directing award where agency mischaracterized an expert opinion and the record plainly required an award)
Dale v. S & S Builders, LLC, 188 P.3d 554 (Wyo. 2008) (explains substantial-evidence standard for agency fact findings)
Watkins v. State ex rel. Wyo. Med. Comm'n, 250 P.3d 1082 (Wyo. 2011) (burden-shifting/substantial evidence review when claimant fails to meet burden)
Kebschull v. State ex rel. Dep't of Workforce Servs., Workers' Comp. Div., 399 P.3d 1249 (Wyo. 2017) (appellate review comes directly from agency; focus on whether agency could reasonably conclude as it did)
In re Pickens, 134 P.3d 1231 (Wyo. 2006) (describes odd-lot doctrine and claimant’s prima facie requirements)
Newman v. State ex rel. Wyo. Workers' Safety & Comp. Div., 49 P.3d 163 (Wyo. 2002) (defines substantial evidence as more than a scintilla and what review entails)