K. Husain v. WCAB (AMN Healthcare, Inc.), K. Husain v. WCAB (AMN Healthcare, Inc.)

Claimant Khadijah Husain, a nursing assistant, injured her left foot on October 16, 2013 when a patient rolled a wheelchair over it; Employer accepted liability for a left foot contusion and issued an NCP.
Claimant did not return to work after the injury and sought ongoing treatment from several physicians; she later alleged the injury included complex regional pain syndrome (CRPS).
Employer filed a termination petition (full recovery as of March 24, 2014); Claimant filed a review petition seeking to add CRPS. The matters were consolidated and litigated before a WCJ.
Competing medical evidence: Employer’s examining podiatrist (Dr. Boc) opined the contusion was fully resolved and no further restrictions were needed; Claimant’s pain management physician (Dr. Sundararajan) diagnosed Type I CRPS and opined Claimant remained disabled from her prior job.
The WCJ credited Dr. Boc over Dr. Sundararajan, found Claimant credible only as to occurrence of the injury (not ongoing disability or CRPS), granted Employer’s termination petition effective March 24, 2014, and denied Claimant’s review petition.
The Workers’ Compensation Appeal Board affirmed. Claimant appealed to this Court arguing capricious disregard of evidence and that the WCJ’s decision was not reasoned; this Court affirmed.

Issue	Husain's Argument	AMN Healthcare's Argument	Held
Whether the WCJ capriciously disregarded or failed to consider contrary evidence when rejecting CRPS and ongoing disability	WCJ ignored or improperly discounted medical and testimonial evidence supporting CRPS and ongoing disability	WCJ considered and expressly rejected contrary evidence; credibility determinations are for the WCJ	Not capricious; WCJ expressly considered and rejected evidence and substantial evidence supports findings
Whether the WCJ’s decision was a "reasoned decision" under Section 422(a) and whether substantial evidence supports denial of the review petition and grant of termination	Decision was insufficiently reasoned and failed to explain rejection of uncontroverted evidence	WCJ provided findings, explained credibility choices, and identified basis for rejecting opinions; substantial evidence supports outcome	Decision was reasoned; substantial competent evidence supports denial of CRPS claim and termination was appropriate

Lombardo v. Workers’ Compensation Appeal Board (Topps Co.), 698 A.2d 1378 (Pa. Cmwlth. 1997) (WCJ is sole finder of fact and credibility determinations will not be disturbed if supported by substantial evidence)
Greenwich Collieries v. Workmen’s Compensation Appeal Board (Buck), 664 A.2d 703 (Pa. Cmwlth. 1995) (substantial evidence standard described)
Berardelli v. Workmen’s Compensation Appeal Board (Bureau of Personnel), 578 A.2d 1016 (Pa. Cmwlth. 1990) (definition of substantial evidence)
Westinghouse Electric Corp. v. Workers’ Compensation Appeal Board (Korach), 883 A.2d 579 (Pa. 2005) (a review petition seeking to add an injury carries same burdens as a claim petition)
Daniels v. Workers’ Compensation Appeal Board (Tristate Transport), 828 A.2d 1043 (Pa. 2003) (defines requirements of a reasoned decision under Section 422(a))