In the Matter of the Worker's Compensation Claim Of: Bennie Johnson v. State of Wyoming, Ex Rel., Wyoming Workers' Safety and Compensation Division, 2014 WY 33

Johnson has a long history of knee problems beginning with a 1985 fall and a 1992 knee-related medical history significant for bilateral patellofemoral issues; the Division initially found the 1992 injury work-related and covered related surgeries, including 1992 bilateral knee procedures; Johnson later sought preauthorization for bilateral total knee replacements and continued treatment, which the Division denied as not related to the 1992 injury; the Medical Commission held a contested-case hearing and admitted three exhibits over Johnson's objection but ultimately upheld the Division's denial; Johnson challenged the admission of the exhibits and the causation finding linking current knee needs to the 1992 injury; the Wyoming Supreme Court reviews under the substantial-evidence standard and assesses whether the Commission acted within its discretionary authority on evidentiary matters and causation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Commission admitted unreliable or irrelevant evidence over objection.	Johnson argues the three exhibits were irrelevant or unreliable.	Division contends the exhibits were offered to address credibility and work history, or were part of the file.	No reversible error; admission was harmless.
Whether the Medical Commission's causation finding is supported by substantial evidence.	Johnson asserts the 1992 cumulative trauma injury caused the knee replacements.	Division contends subsequent injuries, aging, and obesity negate causation to the 1992 injury.	Yes; substantial evidence supports the Commission’s conclusion that current needs were not causally related to the 1992 injury.

Dale v. S & S Builders, LLC, 188 P.3d 554 (Wy. 2008) (substantial evidence review; agency could weigh medical evidence and credibility)
Bush v. State ex rel. Wyo. Workers’ Comp. Div., 120 P.3d 176 (Wy. 2005) (definition of substantial evidence and agency discretion)
Greene v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 204 P.3d 285 (Wy. 2009) (agency discretion in evidentiary rulings; harmless error standard)
Walton v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 153 P.3d 932 (Wy. 2007) (agency handling of evidence; no reversal for unrelated misstep if no reliance in decision)
Huntington v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 163 P.3d 839 (Wy. 2007) (causation and injury definitions; requirement of nexus to employment)
Dr. Hoffman v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 291 P.3d 297 (Wy. 2012) (special medical-expertise deference in worker’s comp cases; weighing of medical opinions)
Stallman v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 297 P.3d 82 (Wy. 2013) (agency weighing of medical opinions; credibility determinations within discretion)
Hathaway v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 317 P.3d 590 (Wy. 2014) (agency special expertise; deferential review of medical causation)