AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Worker, a maintenance employee at Armand Hammer United World College, suffered an on-the-job injury on May 3, 2012, when he stepped or fell out of a pickup, injuring his right great toe. Following two surgical procedures to address the injury, the Worker's condition worsened, developing Chronic Regional Pain Syndrome (CRPS), Type 1, which led to a gait disturbance and secondary mental illness, including panic attacks, chronic pain, depression, and anxiety. The Worker was unable to return to his job duties, and his employment was terminated as the Employer could not accommodate his physical restrictions (paras 3-4).

Procedural History

• Worker filed a complaint on June 26, 2014, seeking benefits under the Workers’ Compensation Act. The case was tried by the Workers’ Compensation Judge (WCJ) on August 30, 2016 (para 4).

Parties' Submissions

• Worker: Argued for seven hundred weeks of permanent partial disability (PPD) benefits for his secondary mental impairment, contended that the WCJ failed to adopt the parties’ pretrial stipulations, and objected to the reliance on the American Medical Association’s Guides to the Evaluation of Permanent Impairment, Sixth Edition (AMA Guides Sixth Edition) for establishing his impairment rating (para 1).
• Employer/Insurer: The specific arguments of the Employer/Insurer are not detailed in the provided text.

Legal Issues

• Whether the WCJ erred in not awarding the Worker seven hundred weeks of PPD benefits for his secondary mental impairment.
• Whether the WCJ erred in failing to adopt the parties’ pretrial stipulations and entered a judgment that went beyond the parties’ requested relief.
• Whether the WCJ erred in relying upon the AMA Guides Sixth Edition in establishing the Worker’s impairment rating.

Disposition

• The Court of Appeals affirmed the WCJ’s decision, which awarded the Worker 100 weeks of PPD benefits for his secondary mental impairment, among other rulings (para 1).

Reasons

• The Court of Appeals found that the WCJ did not err in awarding only 100 weeks of PPD benefits for the Worker's secondary mental impairment, as the application of the law to the facts was reviewed de novo, and the WCJ's decision was in line with statutory provisions and case law precedents. The Court also held that the WCJ did not err in its decision regarding the pre-trial order and the application of the AMA Guides Sixth Edition. The Court reasoned that the WCJ complied with the requirement that benefits awarded for a mental (primary or secondary) impairment stemming from an injury be no less than the benefits awarded for a physical impairment that stems from the same injury. Furthermore, the Court found no unconstitutional delegation of legislative authority in the WCJ's reliance on the AMA Guides Sixth Edition for determining the Worker's impairment rating (paras 5-38).