Roundtree v. Workers' Compensation Appeal Board
116 A.3d 140
| Pa. Commw. Ct. | 2015Background
- In Oct. 2010 Deborah Roundtree (Claimant) filed a workers’ comp claim alleging major depressive disorder beginning Oct. 2007 due to long-term harassment and discrimination while employed by the City of Philadelphia (Employer). She sought medical expenses and disability benefits from Oct. 17, 2007.
- Employer denied the claim; the parties mediated unsuccessfully and proceeded to multiple WCJ hearings in 2011.
- The WCJ repeatedly told Claimant (pro se) she needed unequivocal medical testimony or a scheduled medical deposition to support wage-loss beyond 52 weeks and repeatedly extended deadlines (over a year total).
- Claimant failed to schedule a medical deposition or present medical expert testimony; she attempted to submit medical records but did not present expert testimony.
- On Dec. 14, 2011 the WCJ granted Employer’s motion to dismiss the claim petition without prejudice for Claimant’s failure to comply with deadlines; the Board affirmed.
- The Commonwealth Court affirmed, holding the WCJ did not abuse discretion in denying further continuances and that medical evidence was required because the causal link was not obvious to a layperson.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether dismissing the claim for failure to meet WCJ deadlines violated due process / was an abuse of discretion | Roundtree: as a disabled, unrepresented layperson she needed more time; providers were uncooperative, so dismissal deprived her of due process | Employer: Claimant had repeated warnings and ample time; further delay prejudiced Employer; dismissal appropriate | WCJ/Board/Court: No abuse of discretion; dismissal without prejudice appropriate after repeated extensions and noncompliance; due process not violated |
| Whether medical expert testimony was required or Claimant's lay testimony sufficed to prove causation for psychiatric/occupational disease claims | Roundtree: her lay testimony described symptoms and workplace harassment and should suffice | Employer: psychiatric and environment-based claims require unequivocal medical testimony unless nexus is obvious | Court: Medical evidence required because causal connection (depression from workplace environment) is not obvious to an untrained layperson; lay testimony insufficient |
Key Cases Cited
- City of Philadelphia v. Workers’ Compensation Appeal Board (Rooney), 730 A.2d 1051 (Pa. Cmwlth. 1999) (WCJ continuance decisions reviewed for abuse of discretion)
- Kurtz v. Workers’ Compensation Appeal Board (Waynesburg College), 794 A.2d 443 (Pa. Cmwlth. 2002) (medical evidence not required only where causal link is obvious to a layperson)
- Whiteside v. Workmen’s Compensation Appeal Board (Unisys Corp.), 650 A.2d 1202 (Pa. Cmwlth. 1994) (work-environment injuries require unequivocal medical testimony to establish causation)
- General Electric Co. v. Workmen’s Compensation Appeal Board (Valsamaki), 593 A.2d 921 (Pa. Cmwlth. 1991) (where causal connection is not obvious, claimant must prove causation by unequivocal medical testimony)
- McDonnell Douglas Truck Services, Inc. v. Workmen’s Compensation Appeal Board (Feldman), 655 A.2d 655 (Pa. Cmwlth. 1995) (claimant bears initial burden to establish injury is work-related)