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 appealed an order from the Workers’ Compensation Administration (WCA) that granted the Employer's motion to reconsider the date the Worker reached maximum medical improvement (MMI) and decreased the period for which the Worker was awarded temporary total disability (TTD) benefits. The appeal followed a workplace accident on November 30, 2012, which resulted in the Worker sustaining cervical, lumbar, thoracic, and bilateral elbow strains. The initial determination that the Worker had not reached MMI by October 8, 2014, was challenged, leading to a reconsideration based on medical opinions that suggested an earlier MMI date of March 1, 2013.

Procedural History

• Trujillo v. Los Alamos National Laboratory (Trujillo I), 2016-NMCA-041: The Court reversed the October 2014 order, finding the Worker's injuries were caused by the workplace accident and remanded for further evaluation of the Worker's entitlement to TTD and medical benefits.
• A compensation order entered on July 18, 2016, concluded the Worker's injuries were compensable and had not reached MMI by October 8, 2014.
• The Employer's motion for reconsideration led to a December 6, 2016, order that revised the Worker's MMI date to March 1, 2013, based on medical opinions.

Parties' Submissions

• Worker-Appellant: Argued that the Workers’ Compensation Judge (WCJ) lacked authority to reconsider the MMI date, that the law of the case doctrine and the Court's prior opinion precluded reconsideration, and that the evidence relied upon for the March 1, 2013, MMI date was inadmissible or of little value.
• Employer/Self-Insured/Appellee: Contended that reconsideration was warranted based on a healthcare provider form letter from Dr. Sara Pasqualoni, which opined the Worker reached MMI in March 2013, and supported by an independent medical examination (IME) report from Dr. Paul Legant.

Legal Issues

• Whether the law of the case doctrine precluded the WCJ from reconsidering the Worker’s MMI date.
• Whether the WCJ had the authority under the Rules of Civil Procedure or Section 52-5-9 to reconsider the Worker’s MMI date.
• Whether the evidence relied upon by the WCJ to establish the March 1, 2013, MMI date was admissible and substantial enough to support the conclusion.

Disposition

• The Court reversed the WCJ's order that granted the Employer's motion to reconsider the Worker's MMI date and remanded for limited further proceedings consistent with the Court's opinion and prior mandate.

Reasons

• The Court found that the law of the case doctrine did not preclude reevaluation of the Worker’s MMI date on remand (paras 12-13). It held that the WCJ had the authority under Section 52-5-9 to modify a prior compensation order based on a mistake of law (paras 14-15). However, the Court concluded that the process by which the WCJ determined the Worker reached MMI on March 1, 2013, was inconsistent with the Court's mandate in Trujillo I, particularly because it failed to consider the Worker's bilateral elbow strain in determining the MMI date for all injuries (paras 24-25). The Court emphasized that the WCJ erred in relying exclusively on the IME report and Dr. Pasqualoni’s form letter, which did not address the Worker's bilateral elbow strain, and thus did not comply with the appellate court's mandate to evaluate the Worker's entitlement to TTD and medical benefits for all injuries sustained (para 26).