Worker's Compensation Claim of Little v. State ex rel. Department of Workforce Services, Workers' Compensation Division, 308 P.3d 832

In 1988 Marshall Little suffered a compensable lower‑back/neck injury at work, treated by orthopedists and undergoing at least one lumbar laminectomy in 1989. He received a 27% whole‑body impairment award and had intermittent treatment thereafter.
Little later developed progressive right‑greater‑than‑left hip osteoarthritis first diagnosed radiographically in 2007; by 2009 imaging showed pronounced right hip arthritis and physicians discussed total hip arthroplasty.
Little submitted an $87 office‑visit bill (Dr. Kirti‑kumar Patel, internist) to the Wyoming Workers’ Safety & Compensation Division; Division denied coverage asserting the hip condition was unrelated to the 1988 injury.
At OAH hearing, Little argued either (1) the 1988 accident directly injured his hip, or (2) altered gait/overcompensation from his back injury caused a second compensable hip injury (osteoarthritis) requiring hip replacement.
The Division obtained an independent orthopedic IME (Dr. Torkelson) concluding the hip osteoarthritis was age/degeneration‑related and unrelated to the 1988 accident; Dr. Patel (treating internist) testified it was "possible" the hip disease resulted from overcompensation but used tentative language.
The hearing examiner credited Dr. Torkelson, found Little failed to prove causation under the second compensable injury rule, and denied benefits; the district court affirmed and the Supreme Court likewise affirmed on substantial‑evidence review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Little proved that his hip osteoarthritis (and need for hip replacement) was causally connected to the 1988 work injury (either as direct hip injury or as a "second compensable injury" from overcompensation/altered gait)	Little: treating physician (Dr. Patel) and his history show overcompensation/altered gait from the 1988 injury probably caused progressive right hip osteoarthritis requiring surgery.	Division: independent orthopedic IME (Dr. Torkelson) found no diagnosis of hip osteoarthritis until ~2007 and concluded degeneration is age‑related and not causally linked to the 1988 incident; any early leg pain was attributed to radiculopathy not hip pathology.	Court: Affirmed denial — Little met burden to produce evidence (Dr. Patel) but failed burden of persuasion; hearing examiner reasonably credited orthopedic expert and found substantial evidence to reject causal link.

Jacobs v. State ex rel. Wyo. Workers' Safety & Comp. Div., 301 P.3d 137 (Wyo. 2013) (standard of substantial‑evidence review for agency findings)
Willey v. State ex rel. Wyo. Workers' Safety & Comp. Div., 288 P.3d 418 (Wyo. 2012) (deference to agency credibility determinations)
Yenne‑Tully v. State ex rel. Wyo. Workers' Safety & Comp. Div., 12 P.3d 170 (Wyo. 2000) (second compensable injury rule where a triggering accident exists)
Anastos v. General Chemical Soda Ash, 120 P.3d 658 (Wyo. 2005) (medical expert testimony standard for causation — "more probable than not")
Hoffman v. State ex rel. Wyo. Workers' Safety & Comp. Div., 291 P.3d 297 (Wyo. 2012) (second compensable injury requires causal relation to original injury)