A workers’ compensation judge’s decision granting a Claim Petition is not reasoned as required under Section 422(a) of the Act when the judge’s injury descriptions are too general and lack specifics.

The claimant filed a Claim Petition in which he alleged he sustained work injuries to his left knee, low back and right hip on June 12, 2021. The case was litigated before a workers’ compensation judge. Testimony was given by medical experts for the claimant and the employer. The employer also presented testimony from a company representative regarding attempts made to offer the claimant a modified duty position. Ultimately, the judge granted the Claim Petition, finding the testimony of the claimant and his medical expert to be more credible than the testimony of the employer’s expert. The judge specifically found that the claimant sustained a left knee injury, a right hip injury and a low back injury with radiculopathy. 

The employer appealed to the Workers’ Compensation Appeal Board, which reversed the judge’s decision regarding the right hip injury, concluding that the description was too general. The Appeal Board, however, did accept the judge’s descriptions of the claimant’s low back and left knee injuries. 

The employer then appealed to the Commonwealth Court, arguing that the judge’s decision was not reasoned because of the general descriptions made regarding the claimant’s work injuries. They asked the court to either reverse the Board or remand the case for more specific findings relative to the judge’s descriptions of the injuries.

The Commonwealth Court agreed with the employer and reversed the Appeal Board. According to the court, the judge’s findings relative to the claimant’s compensable injuries were not sufficiently specific to be considered reasoned under Section 422(a) of the Act. According to the court, the absence of specificity leaves the parties, future workers’ compensation judges and the court guessing as to the exact injury description that will frame the issues in any subsequent litigation. The court, therefore, remanded the case for additional findings of fact and conclusions of law from the judge as to the description, extent and/or scope of the claimant’s left knee and low back injuries. 

_{What’s Hot in Workers’ Comp, Vol. 28, No. 10, October 2024, 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 © 2024 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.}