J. Willis v. DOWCP
23-2048
4th Cir.May 28, 2025Background
- J. Larry Willis, an employee at Virginia International Terminals, hurt his back in May 2018 driving a translifter into a pothole.
- Willis received benefits for some periods related to temporary disability but claimed he was entitled to more under the Longshore and Harbor Workers’ Compensation Act (Longshore Act).
- An Administrative Law Judge (ALJ) denied additional benefits, finding Willis’ current back issues were primarily due to pre-existing degeneration, not the 2018 work injury.
- The ALJ determined Willis' testimony was not credible because he failed to disclose his long history of prior back problems to his doctors after the accident.
- The Benefits Review Board (BRB) affirmed the ALJ’s decision, and Willis petitioned the Fourth Circuit for review.
- The court reviewed whether the ALJ’s decision was supported by substantial evidence and adequately explained under the APA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are ALJ’s findings supported by substantial evidence? | Willis claimed ALJ wrongly discounted his evidence | Extensive pre-existing condition, lack of candor | ALJ’s findings are supported by substantial evidence |
| Did ALJ adequately explain decision (APA standard)? | ALJ failed to address all relevant evidence | ALJ sufficiently explained reasons | ALJ’s explanation was sufficient under the APA |
| Credibility of Willis’ testimony | Testimony about no prior pain was credible | Omission showed intent to downplay old injuries | ALJ properly found testimony not credible |
| Weighing of expert opinions | Dr. Wardell’s causation opinion should control | Dr. Goss' opinion grounded in full history | ALJ reasonably credited Dr. Goss over Dr. Wardell |
Key Cases Cited
- Ceres Marine Terminals, Inc. v. Green, 656 F.3d 235 (4th Cir. 2011) (affirms deference to ALJ’s factual findings and credibility determinations)
- Gilchrist v. Newport News Shipbuilding & Dry Dock Co., 135 F.3d 915 (4th Cir. 1998) (standard for reviewing BRB and ALJ decisions under Longshore Act)
- Metro Mach. Corp. v. DOWCP, 846 F.3d 680 (4th Cir. 2017) (scope of de novo review for legal issues by appellate courts)
- Island Creek Coal Co. v. Blankenship, 123 F.4th 684 (4th Cir. 2024) (defines substantial evidence standard and ALJ’s duty of explanation)