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In the Matter of the Worker's Compensation Claim of: Steve Hampton v. State of Wyoming, ex rel., Wyoming Workers' Safety and Compensation Division
296 P.3d 934
Wyo.
2013
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Background

  • Appellant Hampton injured in a 1996 work accident; later diagnosed with a left shoulder labral tear in 2009.
  • Division denied benefits for the left shoulder condition, and OAH and the district court affirmed.
  • 1998 MRI showed no tear; 2009 MRI with gadolinium revealed a tear.
  • Medical opinions conflicted: Dr. Kaplan rejected causation; Dr. Gorman linked tear to 1996 accident.
  • Appellant bore the burden of proving the tear was caused by the 1996 accident.
  • Court affirms denial, finding substantial evidence supports causation-based denial and no evident arbitrariness.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Was the denial supported by substantial evidence? Hampton argues substantial evidence supports causation. Division asserts lack of causation evidence. Yes; substantial evidence supports denial.
Was the decision arbitrary and capricious? OAH failed to credibly assess witnesses. Record shows RMA weighed conflicting medical opinions. No; decision not arbitrary or capricious.

Key Cases Cited

  • Dale v. S & S Builders, LLC, 188 P.3d 554 (Wy. 2008) (substantial evidence standard of review in agency actions)
  • Newman v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 49 P.3d 163 (Wy. 2002) (reviewing agency decisions without deference to district court)
  • Nagle v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 190 P.3d 159 (Wy. 2008) (testimony of injured worker may prove accident if uncontradicted and corroborated)
  • Gray v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 193 P.3d 246 (Wy. 2008) (medical proof not always required for causal connection in immediate injuries)
  • Thornberg v. State ex rel. Wyo. Workers’ Comp. Div. (In re Thornberg), 913 P.2d 863 (Wy. 1996) (causation requires more than undetectable immediate link; timing matters)
Read the full case

Case Details

Case Name: In the Matter of the Worker's Compensation Claim of: Steve Hampton v. State of Wyoming, ex rel., Wyoming Workers' Safety and Compensation Division
Court Name: Wyoming Supreme Court
Date Published: Feb 8, 2013
Citation: 296 P.3d 934
Docket Number: S-12-0076
Court Abbreviation: Wyo.