Jeffrey Frazier v. Mato Corporation, 20-0406

Jeffrey Frazier injured his left elbow slipping on ice on February 22, 2013; claim held compensable for left elbow contusion.
Initial imaging showed no fracture; conservative treatment followed. Claim was referred for permanent impairment evaluation under the AMA Guides (4th ed.).
Dr. Joseph Grady (claims administrator IME, Sept. 2017) found the contusion resolved and assigned 0% whole‑person impairment.
Dr. Robert Walker (treating/occupational medicine, Feb. 2019) measured ROM deficits and rated 10% upper‑extremity impairment, converted to 6% whole‑person impairment attributable to the compensable injury.
Dr. Prasadarao Mukkamala (independent physiatrist, Aug. 2019) found normal ROM, no neurovascular deficit, MMI, and 0% impairment.
The Office of Judges (Dec. 2019) and the Board of Review (May 2020) affirmed the 0% award, finding Grady and Mukkamala persuasive and Walker an outlier; the Supreme Court of Appeals affirmed.

Issue	Frazier's Argument	Mato's Argument	Held
Whether Frazier is entitled to permanent partial disability for the 2013 left elbow contusion	Dr. Walker’s ROM measurements support 10% UE → 6% WPI; residual impairment exists	Independent IMEs (Drs. Grady & Mukkamala) found the injury resolved and 0% impairment under AMA Guides	Affirmed: 0% PPD. Board and Office found Grady and Mukkamala persuasive; Walker was an outlier

Hammons v. W. Va. Off. of Ins. Comm’r, 235 W. Va. 577 (2015) (sets out deference to board findings and limited grounds for reversal)
Justice v. West Virginia Office Insurance Commission, 230 W. Va. 80 (2012) (applies de novo review to legal questions arising from board decisions)
Davies v. W. Va. Off. of Ins. Comm’r, 227 W. Va. 330 (2011) (addresses standard of review for legal issues in workers’ compensation appeals)