Mullin v. Duckworth Alco, 2016 Ark. App. 122

Michelle Mullin had a long history of chronic neck, back, and shoulder problems, including two prior lumbar surgeries and a 2011 nonwork shoulder injury.
She sustained two compensable workplace injuries while employed by Alco: April 11, 2011 (treated, rotator-cuff surgery, released to full duty December 8, 2011) and May 3, 2013 (complained of neck, shoulder, back pain, headaches).
After the 2013 injury she was treated conservatively and referred to neurosurgeon Dr. Schlesinger, whose review of imaging showed moderate–severe cervical degenerative changes; he could not definitively attribute symptoms to the workplace incidents but recommended cervical epidural steroid injections and released her to light duty.
Employer contested further treatment and benefits; Mullin filed for additional medical treatment and temporary-total-disability (TTD) benefits with the Arkansas Workers’ Compensation Commission.
The ALJ denied additional medical treatment and TTD benefits; the Full Commission affirmed, finding Mullin failed to prove a causal link between her ongoing symptoms/treatment and the 2011 or 2013 compensable injuries and that she was not totally incapable of earning wages.
On appeal to the Court of Appeals, the court affirmed, emphasizing chronic preexisting degenerative conditions in the record and credibility concerns (including a treating physician’s prior finding that Mullin had been dishonest about symptoms).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mullin proved that steroid injections and ongoing medical care were reasonable, necessary, and causally related to the 2011/2013 work injuries	Mullin: Objective findings had not disappeared and recommended injections are related to compensable injuries; she has not reached MMI and needs further care	Employer: Imaging and doctor opinions show degenerative, chronic etiology predating work incidents; causal connection to compensable events not proven	Affirmed denial — Commission had substantial evidence to find lack of causal connection and that ongoing treatment was not reasonably necessary for the compensable injuries
Whether Mullin was entitled to temporary-total-disability benefits	Mullin: Ongoing symptoms prevent work and she remains in healing period	Employer: Mullin was released to light duty and no evidence shows total incapacity to earn wages	Affirmed denial — substantial evidence that she was released to light duty and not totally incapacitated