Court Affirms Benefits for Aggravation of Preexisting Knee Condition Despite Employer’s Challenge

The Commonwealth Court of Pennsylvania affirmed a decision awarding benefits to a claimant who claimed his work duties aggravated a preexisting right knee condition, ultimately requiring a total knee replacement. The employer argued that the claimant’s testimony was contradicted by medical evidence showing significant prior knee problems and that the workers’ compensation judge failed to issue a reasoned decision. The court rejected these arguments, holding that the judge acted within their discretion to credit the claimant’s testimony and expert opinion and provided an adequately reasoned decision supported by substantial evidence.

The claimant filed a petition alleging that, while working for the employer, he sustained an injury on May 21, 2021, that aggravated underlying degenerative joint disease in his right knee. The claimant worked as a heavy-duty bus technician for the employer, and on the date of injury, he was installing a brake drum wheel and tire assembly on a bus. The claimant continued working through July, 2022, when he underwent a right total knee replacement. 

During the course of litigation, the claimant testified that he suffered a prior work injury to his right knee in 2017 and that he underwent a right knee arthroscopy 25 years before that injury. The employer’s medical expert reviewed medical records as part of his evaluation and testified that the claimant’s right knee was more of an issue before the work injury than the claimant let on, in that the claimant was treating for it and contemplating a right knee replacement in 2020. 

The workers’ compensation judge granted the petition, finding that the claimant sustained a lumbar strain and sprain and an aggravation of his right knee condition. In the decision, the judge recognized that it was a close call but found, on balance, the claimant to be credible. The Appeal Board affirmed on appeal. 

On appeal to the Commonwealth Court, the employer argued that the claimant’s testimony was directly contradicted by other credible evidence of record; therefore, the judge erred in granting the petition. The employer’s argument was rejected, and their appeal dismissed. The Commonwealth Court noted that a judge, as fact finder, has complete authority over questions of witness credibility and evidentiary weight. They further noted that the judge is free to accept or reject the testimony of any witness, including a medical witness, in whole or in part. They found that the judge’s decision to credit the testimony of the claimant’s expert was supported by substantial evidence. 

The court also rejected the employer’s argument that the judge failed to issue a reasoned decision, as required under Section 422 (a) of the Act. According to the court, the fact that the judge chose to grant relief is not a basis for determining that a decision is not reasoned, and Section 422 (a) of the Act does not permit a party to second-guess the judge’s reasons for credibility determinations. 

_{What’s Hot in Workers’ Comp, Vol. 29, No. 8, August 2025, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. We would be pleased to provide such legal assistance as you require on these and other subjects when called upon. ATTORNEY ADVERTISING pursuant to New York RPC 7.1 Copyright © 2025 Marshall Dennehey, all rights reserved. No part of this publication may be reprinted without the express written permission of our firm. For reprints or inquiries, or if you wish to be removed from this mailing list, contact tamontemuro@mdwcg.com.}