State Ex Rel. Wyoming Workers' Safety & Compensation Division v. Singer, 2011 WY 57

Singer sustained a work-related injury in 2002 with 30% whole body impairment (PPI) determined in 2003, yielding a PPI award of $22,118.45.
In 2004 Singer received a permanent partial disability award totaling $49,009.94 for the same injury.
In 2009 the Division awarded Singer a permanent total disability (PTD) benefit of $202,000.80 due to progression of the injury.
The Division reduced the PTD by $49,009.94 (PPD) and $22,118.45 (PPI), and discounted for lump-sum election, totaling $115,159.18 paid to Singer.
Singer agreed that the PPD deduction was proper but objected to deducting the PPI award, leading to contested case proceedings.
The Hearing Examiner held that the PPI deduction should have been applied; the district court certified the matter to the Wyoming Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prior impairment awards must be deducted from PTD per §27-14-406	Singer: impairment deduction should not apply; only disability awards deductible.	Division: all prior awards involved in impairment must be deducted from PTD.	Deduction of prior impairment award required; remanded for order consistent with this ruling.

Sinclair Oil v. Wyoming Dep't of Revenue, 2010 WY 122 (Wy. 2010) (statutory interpretation guiding ambiguity analysis)
Deloges v. State ex rel. Wyo. Workers' Compensation Division, 750 P.2d 1329 (Wyo. 1988) (pari materia and in pari materia interpretation)
Taylor v. State ex rel. Wyo. Workers' Safety & Comp. Div., 72 P.3d 799 (Wyo. 2003) (double recovery principles in workers' compensation)
Himes v. Petro Engineering and Construction, 61 P.3d 393 (Wy. 2003) (distinction between impairment and ability to work)
McCarty v. Bear Creek Uranium Company, 694 P.2d 93 (Wy. 1985) (impairment vs. disability concept in WC Act)