Jones v. Connecticut Children's Medical Center Faculty Practice Plan, 131 Conn. App. 415

Jones, an advanced practice registered nurse, worked for Connecticut Children's Medical Center Faculty Practice Plan starting December 2002.
On February 27, 2006, while driving for work, a truck tire detached and struck Jones's vehicle, causing injury and subsequent headaches, neck/shoulder pain, and nausea.
Jones received multiple medical evaluations, including emergency department visits, imaging, and specialist consultations, with varying assessments (post-concussive syndrome, anxiety, neurogenic bladder, etc.).
In June 2006, the employer entered into a voluntary agreement accepting a work-related injury to concussion and related body parts, including a 10% PPD of the brain (not accepted by Jones).
The commissioner found lack of evidence for certain acute brain injury symptoms but concluded the accident was a substantial factor in emotional/psychological sequelae; awarded 10% PPD and limited liability pending treatment compliance.
The workers' compensation board reversed, challenging causation for the psychiatric injury and the neurogenic bladder, and declined to treat the agreement as a judicial admission; Jones appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the MVA was a substantial factor in the plaintiff's psychiatric injury	Jones argues Sass and Wade support causation; asserts objective evidence links to brain injury and emotional sequelae.	Employer contends record shows no medical basis that MVA caused psychiatric issues; credibility issues undermine causation.	Board proper to conclude no sufficient evidence that MVA was a substantial factor.
Whether the neurogenic bladder was caused by the MVA	Murphy-Setzko's deposition supports causation from the MVA.	Murphy-Setzko relied on Wade and plaintiff history; records and other experts undermine causation.	Board's rejection of Murphy-Setzko's causation finding affirmed; insufficient causal link established.
Whether the employer could contest compensability and disability rating despite a prior agreement	Employer is precluded from challenging causation/diagnosis based on June 2006 agreement and subsequent Wade rating.	Precludes review problem; the claim was not raised below and cannot be raised on appeal; ambush concerns.	Claim not reviewed; not raised below; affirmed not reviewing this issue.

Williams v. State, 124 Conn. App. 759 (2010) (limits on appellate deference to commissioner findings in workers' comp)
DiNuzzo v. Dan Perkins Chevrolet Geo, Inc., 294 Conn. 132 (2009) (reasonableness standard for expert causation testimony)
Labadie v. Norwalk Rehabilitation Services, Inc., 274 Conn. 219 (2005) (proximate cause standard in workers' compensation)
Voronuk v. Electric Boat Corp., 118 Conn.App. 248 (2009) (proximate cause and evidentiary standard in causation findings)
Vaillancourt v. Latifi, 81 Conn.App. 541 (2004) (causation in fact vs proximate cause in workers' comp)