In the Matter of the Worker's Compensation Claim of: Jeffrey Baker v. State of Wyoming, ex rel., Department of Workforce Services, Workers' Compensation Division, 2017 WY 60

On November 4, 2013 Baker injured his right shoulder at work. Initial treatment and imaging focused on the shoulder; shoulder surgery and carpal tunnel release were performed and covered by the Division.
Baker continued to report right arm numbness/tingling; EMG studies found carpal tunnel but no cervical radiculopathy; later cervical MRI showed multilevel degenerative changes and marked C6–C7 bulging.
Neurosurgeon Dr. Karandikar recommended cervical fusion (ultimately a C5–C7 ACDF was performed in April 2015); the Division denied preauthorization and later denied Baker’s request for temporary total disability (TTD) benefits related to the cervical condition.
Baker sought TTD for a cervical injury he claimed arose simultaneously with the shoulder injury and appealed the Division’s denial to the Medical Commission and then to district court; the Commission found he failed to prove causation and the district court affirmed.
The Commission reviewed competing expert testimony (three experts for Baker, three for the Division), found flaws in all opinions, specifically discounted Dr. Karandikar’s opinion as based on incomplete/incorrect history and found Dr. Murphy’s causation testimony equivocal.
The Wyoming Supreme Court reviewed under the substantial-evidence standard and affirmed, holding Baker failed to prove, by a preponderance and to a reasonable degree of medical probability, that the cervical condition was causally related to the workplace accident.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Baker proved causal link between workplace accident and cervical injury	Baker: medical experts established that the accident simultaneously caused/aggravated the cervical condition	Division: claimant failed to prove causation; Division not required to disprove causation	Held: No — substantial evidence supports Commission’s finding that Baker failed to prove causation
Whether expert opinions relied on met required medical-probability standard	Baker: treating surgeons’ opinions (Karandikar, Murphy) and PT support causation	Division: experts identified weaknesses; some opinions were equivocal or based on incomplete history	Held: Court agreed Commission reasonably discounted equivocal or unsupported opinions; Baker did not meet burden
Whether Commission’s rejection of Baker’s experts was arbitrary/capricious	Baker: Commission ignored or improperly discounted expert conclusions	Division: Commission acted within factfinding role to weigh credibility and probative value	Held: Not arbitrary or capricious — Commission reasonably weighed evidence and explained credibility concerns
Whether arbitrary-and-capricious review applies given evidentiary record	Baker: argued Commission’s findings were arbitrary/capricious	Division: no showing Commission excluded admissible evidence or failed required findings	Held: A/C standard inapplicable; record-based disagreements are for substantial-evidence review

Price v. State ex rel. Dep’t of Workforce Servs., Workers’ Comp. Div., 388 P.3d 786 (Wyo. 2017) (standard for appellate review of agency findings)
Guerrero v. State ex rel. Dep’t of Workforce Servs., Workers’ Comp. Div., 352 P.3d 262 (Wyo. 2015) (definition and application of substantial evidence)
Middlemass v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 259 P.3d 1161 (Wyo. 2011) (language required in medical causation opinions; “could”/“possibly” insufficient)
Johnson v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 321 P.3d 318 (Wyo. 2014) (agency may disregard medical opinion based on incomplete or inaccurate history)
Rogers v. Russell Constr. Co., Inc., 376 P.3d 1172 (Wyo. 2016) (uncontradicted expert opinion may be disregarded if not adequately supported by facts)
In re Claim of Hood, 382 P.3d 772 (Wyo. 2016) (burden of proof and use of arbitrary-and-capricious standard as a safety net)