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 claimant, an employee of the City of Albuquerque, suffered a workplace injury on January 30, 1989, after falling in a storeroom. She held an administrative position in the City's Weed and Litter Division. Following the accident, she experienced various ailments, including headaches, neck, shoulder, lower back, and leg pain. She also suffered two falls at home, injuring her fingers. A CT scan revealed a disc protrusion at L5-S1, but her treating physicians released her to work without restrictions for most of 1989. In 1990, she was diagnosed with multiple sclerosis, which was not attributed to the workplace injury (paras 3-4, 12).
Procedural History
- Workers' Compensation Administration: The Administration issued a disposition order ruling that the claimant had no residual disability from the January 30, 1989, accident as of March 26, 1990.
Parties' Submissions
- Claimant-Appellant: Argued that she remained disabled due to the workplace injury and that the Workers' Compensation Judge (WCJ) erred in finding otherwise. She contended that her medical conditions, including the disc protrusion, caused ongoing pain and disability (paras 1, 11).
- Respondent-Appellee (City of Albuquerque): Asserted that the claimant failed to meet her burden of proving disability after March 25, 1990. The City argued that her medical complaints were unrelated to the workplace injury and that her multiple sclerosis and other conditions were not caused or aggravated by the accident (paras 1, 12).
Legal Issues
- Did the claimant meet her burden of proving that she was disabled after March 25, 1990, due to the workplace injury?
- Should the burden of persuasion have shifted to the City of Albuquerque when it filed a petition to reduce benefits?
Disposition
- The Court of Appeals of New Mexico affirmed the decision of the Workers' Compensation Administration, ruling that the claimant failed to establish her entitlement to benefits after March 25, 1990 (para 21).
Reasons
Per Hartz J. (Minzner C.J. and Apodaca J. concurring):
- The Court held that the burden of persuasion remained with the claimant to prove her entitlement to benefits, even though the City filed a petition to reduce benefits. Public policy considerations, including encouraging employers to voluntarily pay benefits, supported this allocation of the burden (paras 6-10).
- The WCJ's decision was rational and supported by substantial evidence. Medical testimony indicated that the claimant's multiple sclerosis, headaches, and other complaints were not caused by the workplace injury. The disc protrusion at L5-S1 was deemed minor and unlikely to cause significant pain or disability (paras 12-17).
- The claimant's credibility was questioned due to inconsistencies in her accounts of the accident and medical records suggesting symptom exaggeration. The WCJ was entitled to weigh this evidence and determine that the claimant's complaints of pain were not credible (paras 15-16).
- The Court declined to consider evidence from the supplemental record, as it was not before the WCJ at the time of the original decision. The claimant did not appeal the denial of her application to modify the disposition order (paras 19-20).