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

• In 2007, following a motor vehicle collision, the Worker underwent surgery for a complex tear in the medial meniscus of his left knee, which also exhibited "age-appropriate degenerative changes." On October 26, 2015, while performing his duties as a water meter reader, the Worker stumbled and twisted his left knee, leading to a claim for workers' compensation filed on May 12, 2017. The Worker was evaluated by three physicians, all agreeing he is a candidate for total knee replacement (TKR). Two physicians concluded the injury was a temporary exacerbation of preexisting arthritis, while one determined it was an aggravation of the preexisting condition (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Worker-Appellee: Argued that the workplace injury in October 2015 was an aggravation of his preexisting left knee condition, leading to his current disability and need for TKR.
• Employer/Insurer-Appellants: Contended that the Worker's need for TKR is causally related to the 2007 motor vehicle accident and previous surgery, not the work accident. They argued that the Workers’ Compensation Judge (WCJ) erred by relying on the testimony of only one of the three evaluating doctors, whose opinion did not meet the causation standards under relevant law (paras 1, 4).

Legal Issues

• Whether the WCJ erred in relying on the testimony of a single doctor to establish causation for the Worker's need for TKR as related to the work accident.
• Whether the Worker’s need for TKR is causally related to the work accident or to a previous motor vehicle accident and surgery (para 1).

Disposition

• The compensation order from the Workers’ Compensation Judge awarding workers’ compensation benefits to the Worker was affirmed (para 18).

Reasons

• The Court, consisting of Judges Gerald E. Baca, J. Miles Hanisee, and Shammara H. Henderson, found substantial evidence supporting the WCJ's decision. The Court noted that New Mexico law entitles employees to benefits when a preexisting condition combines with a work-related injury to cause disability. The testimony of Dr. Eric Sides, who diagnosed the Worker's condition as an aggravation of preexisting osteoarthritis due to the work injury, was deemed sufficient to establish causation under Section 52-1-28. The Court rejected the Employer's challenge that Dr. Sides had an incomplete understanding of the Worker's medical history, finding that Dr. Sides was informed of pertinent prior injuries. The Court also found that the WCJ was correct in resolving the conflicting medical opinions in favor of the Worker, based on the credible evidence provided by Dr. Sides. The Court concluded that the whole record review supported the WCJ's findings and affirmed the compensation order and order on the motion for reconsideration (paras 5-18).