Worker's Compensation Claim of Delacastro v. State ex rel. Wyoming Workers' Safety & Compensation Division, 321 P.3d 327

In June 2007 Delacastro injured his right hip at work while carrying boxes; he was diagnosed with a right hip strain and lateral femoral cutaneous nerve irritation and received physical therapy.
Symptoms improved by September 2007, he left his job, and did not pursue further treatment until 2009, when he reported back, bilateral thigh pain, and foot numbness.
Treating physicians diverged: Dr. Pettine suspected an annular tear at L2–L3 (recommended discography); Dr. Williams (IME) concluded the 2007 injury was a right hip strain and found no basis for a lumbar diagnosis or further lumbar treatment.
The Division denied coverage for 2009 back testing/treatment as unrelated to the 2007 hip injury; Delacastro sought administrative review and a contested case hearing at OAH.
OAH authorized a discography on a "rule out" basis (to determine whether lumbar pathology explained his symptoms), ordered payment of medical bills up through the discography, and then denied further lumbar testing/treatment after the discography was negative.
The district court affirmed OAH; on appeal the Wyoming Supreme Court held substantial evidence supported OAH's conclusion that Delacastro failed to prove his back problems were related to the 2007 work injury, but clarified that future treatment related to the original hip injury remains administratively reviewable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether OAH improperly denied all future medical benefits for ongoing right hip/thigh pain	Delacastro contends OAH's order effectively denied all future benefits including for the compensable hip injury	Division argues OAH recognized the compensable hip injury and any future hip treatment may be separately pursued administratively	OAH may not be read to bar future hip-related treatment; decision modified to allow separate administrative review for future hip treatment
Whether OAH erred in denying additional diagnostic testing/treatment for the lumbar spine after a negative discography	Delacastro argues the record does not support denial of further lumbar testing (e.g., nerve block) after discography	Division contends the negative discography undermines causal connection to the 2007 injury and no further lumbar procedures are supported	Substantial evidence supports OAH's denial of additional lumbar testing/treatment because the negative discography validated the view that lumbar spine was not the source and Delacastro failed to meet his burden of proving causation

Snyder v. State ex rel. Wyo. Workers' Comp. Div., 957 P.2d 289 (Wyo. 1998) (diagnostic tests may be compensable on a "rule out" basis even if they ultimately reveal no work-related injury)
Mitcheson v. State ex rel. Wyo. Workers' Safety & Comp. Div., 277 P.3d 725 (Wyo. 2012) (to be compensable under rule-out doctrine, employee must show objective indication of a physiologic connection between injury and diagnostic measure)
Dale v. S & S Builders, LLC, 188 P.3d 554 (Wyo. 2008) (standard for reviewing agency findings: substantial evidence and evaluating whether agency could reasonably reach its conclusion)
Kenyon v. State ex rel. Wyo. Workers' Safety & Comp., 247 P.3d 845 (Wyo. 2011) (claimant bears burden to prove causation by a preponderance of the evidence)
Watkins v. State ex rel. Wyo. Workers' Safety & Comp. Div., 250 P.3d 1082 (Wyo. 2011) (agency may disregard expert opinion if unsupported by facts, based on incomplete history, or otherwise unreasonable)