S.L. Brown v. WCAB (Abington Memorial Hospital), 2040 C.D. 2016

Claimant (Brown) injured at work in Aug 2012 when a patient and recliner fell on her; Employer issued an NCP accepting right foot contusion and low back strain.
Claimant filed a review petition seeking to add CRPS/RSD, right sacroiliitis, adjustment disorder with anxious/depressed mood, and chronic pain; Employer filed a termination petition asserting full recovery.
Hearings: Claimant testified to persistent right foot and lower‑back/groin pain, use of crutches, implanted spinal stimulator, sleep/appetite loss, and treatment by a pain‑management physician and a psychologist.
Medical testimony conflicted: Claimant’s treating pain physician diagnosed RSD and opined disability; Employer’s physiatrist found no objective signs of RSD (normal bone scan and normal exam) and opined Claimant recovered from accepted injuries.
WCJ credited Claimant and her psychologist for psychological injury and chronic pain, but credited Employer’s physician over Claimant’s physician on RSD and denied addition of RSD to the NCP; WCJ amended NCP to add adjustment disorder and chronic pain.
The Board affirmed rejection of RSD but reversed the chronic‑pain amendment and treated Employer’s termination as a modification terminating benefits for the accepted contusion and strain while preserving benefits for the psychological injury. Claimant appealed.

Issue	Brown's Argument	Abington's Argument	Held
Whether NCP should be amended to add CRPS/ RSD	All treating doctors diagnosed RSD; WCJ and Board erred in crediting Employer’s expert and in rejecting RSD	Employer’s expert found no objective signs of RSD (normal bone scan, normal exam); WCJ properly credited him	Court affirmed: WCJ reasonably credited Employer’s physician and gave adequate reasons; RSD not proven for amendment of NCP
Whether NCP should be amended to add chronic pain (and whether termination was improper)	WCJ credibly found ongoing physical and psychological injury; chronic pain can be accepted based on claimant’s credible testimony and WCJ’s findings	Psychologist’s chronic‑pain opinion depended on assumed RSD; because RSD was rejected, psychologist’s opinion is incompetent; Employer entitled to termination of accepted contusion/strain	Court affirmed Board: psychologist’s chronic‑pain diagnosis rested on rejected RSD finding, so it cannot support amendment; Board properly modified NCP and terminated benefits for the accepted physical injuries while preserving psychological benefits

Daniels v. Workers’ Comp. Appeal Bd. (Tristate Transp.), 828 A.2d 1043 (Pa. 2003) (WCJ must provide reasoned decision specifying evidence and reasons for credibility choices)
Dorsey v. Workers’ Comp. Appeal Bd. (Crossing Constr. Co.), 893 A.2d 191 (Pa. Cmwlth. 2006) (when experts testify by deposition, WCJ must articulate objective bases for preferring one expert over another)
Meadow Lakes Apartments v. Workers’ Comp. Appeal Bd. (Spencer), 894 A.2d 214 (Pa. Cmwlth. 2006) (factfinder may expand NCP to include pain corroborated by credible testimony even without a formal medical label)
Campbell v. Workers’ Comp. Appeal Bd. (Antietam Valley Animal Hosp.), 705 A.2d 503 (Pa. Cmwlth. 1998) (claimant’s credited testimony of pain may justify NCP expansion absent a formal diagnosis)
Cinram Mfg., Inc. v. Workers’ Comp. Appeal Bd. (Hill), 975 A.2d 577 (Pa. 2009) (Section 413(a) corrective amendment standard for NCP)
Phoenixville Hosp. v. Workers’ Comp. Appeal Bd. (Shoap), 81 A.3d 830 (Pa. 2013) (scope of appellate review: substantial evidence, legal error, constitutional claims)