Lane-Walter v. State Ex Rel. Wyoming Workers' Safety & Compensation Division
2011 WY 52
| Wyo. | 2011Background
- Lane-Walter sustained a work-related back injury (1984) and entered a 1997 settlement with the Division settling future disability claims and imposing conditions for medical evaluations and paid treatments.
- She later underwent X STOP interspinous decompression surgery (Feb. 15, 2008) after the Division told her preauthorization was not required.
- The Division and Medical Commission denied related medical bills as not reasonable or medically necessary.
- Lane-Walter had relied on representations that preauthorization was unnecessary and on multiple prior medical opinions and records.
- The district court affirmed the Medical Commission’s denial; the Wyoming Supreme Court reversed and remanded with directions to pay the X STOP-related medical claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Burden of proof allocation, who bears burden. | Lane-Walter bears burden; Division should not. | Division bears burden to show lack of reasonableness/necessity. | Burden on claimant; reversal of the failure to pay. |
| Whether the Medical Commission omitted material evidence. | Evidence favorable to Lane-Walter was omitted. | Record supported the Commission's findings. | No substantial compliance; remand for proper consideration. |
| Use of FDA preauthorization guidelines to determine reasonableness and necessity. | Guidelines not applicable to her claim; preauthorization not required. | Guidelines should guide reasonableness/necessity determinations. | Guidelines misapplied; not controlling to denial here. |
Key Cases Cited
- Dale v. S & S Builders, LLC, 2008 WY 84 (Wyo. 2008) (settlement context; standard of review for evidentiary rulings)
- Palmer v. State ex rel. Wyo. Workers' Safety & Comp. Div., 2008 WY 105 (Wyo. 2008) (defining medically necessary benefits under the act)
- Guier v. Teton County Hosp. Dist., 2011 WY 31 (Wyo. 2011) (burden of proof allocation on appeal in WC cases)
- Kenyon v. State ex rel. Wyo. Workers' Safety & Comp. Div., 2011 WY 14 (Wyo. 2011) (claimant bears burden of proving all elements of claim)
- Bailey v. State ex rel. Wyo. Workers' Safety & Comp. Div., 2010 WY 152 (Wyo. 2010) (presenting/allocating evidentiary burden)