Watkins v. STATE EX REL. WYO. MED. COM'N
2011 WY 49
| Wyo. | 2011Background
- Appellant Paul Watkins sustained a work-related back injury on January 2, 2007 after jumping from a trailer tire, leading to initially awarded temporary total disability (TTD).
- The Division later denied further TTD benefits and medical treatment beyond February 17, 2007, on the grounds of lack of relation to the work injury and pre-existing conditions.
- Dr. Williams performed an independent medical examination on May 21, 2007, concluding no direct causal link between the work injury and need for lumbar fusion and that the Division was not responsible for further treatment.
- The Wyoming Medical Commission held a contested case hearing and determined Watkins reached maximum medical improvement (MMI) on May 21, 2007 and denied ongoing treatment and further TTD benefits thereafter.
- The district court affirmed the Commission’s decision, and the Wyoming Supreme Court affirmed the district court, with Justice Hill dissenting.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Commission’s denial of further TTD benefits is supported by substantial evidence | Watkins argues there is no substantial evidence the condition stabilized by May 21, 2007. | Division argues the IME and credibility determinations support stabilization and cessation of TTD. | Yes; substantial evidence supports denial of further TTD. |
| Whether Dr. Williams' IME report was properly admitted and considered | IMe report was improperly admitted and relied upon without Watkins testifying; lacks foundation for future treatment. | IME report was admissible in administrative proceedings and probative as corroborative, even if not fully dispositive. | Yes; IME report properly admitted and considered. |
| Whether the Commission’s credibility determinations were supported by substantial evidence | Watkins asserts the credibility findings were unfounded and biased against him. | Commission credibility determinations are within its exclusive province and should be deferred absent clear weight of evidence against them. | Yes; credibility determinations were supported by substantial evidence. |
| Whether the Commission properly discounted Dr. Beer’s opinions | Beer's opinions should be given more weight as he treated Watkins and reviewed extensive records. | Beer's opinions rested on subjective reporting and inconsistent with medical evidence; properly discounted. | Yes; the Commission properly discounted Beer's opinions. |
Key Cases Cited
- Dale v. S & S Builders, LLC, 188 P.3d 554 (Wy. 2008) (substantial evidence standard and defer to agency credibility findings)
- Newman v. State ex rel. Wyo. Workers' Safety & Comp. Div., 49 P.3d 163 (Wy. 2002) (review de novo with no deference to district court)
- Jensen v. State ex rel. Wyo. Workers' Safety & Comps. Div., 24 P.3d 1133 (Wy. 2001) (substantial evidence standard for agency decisions)
- Glaze v. State ex rel. Wyo. Workers' Safety & Comp. Div., 214 P.3d 228 (Wy. 2009) (deference to agency credibility determinations)
- Tarraferro v. State ex rel. Wyo. Med. Comm'n, 123 P.3d 912 (Wy. 2005) (pain testimony and medical evidence in workers’ comp claims)
- Gray v. State ex rel. Wyo. Workers' Safety & Comp. Div., 193 P.3d 246 (Wy. 2008) (administrative hearsay admissibility in agency actions)
- Wyo Bancorporation v. Bonham, 527 P.2d 432 (Wy. 1974) (principles of administrative review and record supplementation)