This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A licensed practical nurse sustained a 50% permanent impairment to her left knee after a reverse osmosis machine fell on her at work. She also had a preexisting 16% permanent impairment in her right knee, unrelated to the workplace accident. The Workers’ Compensation Judge (WCJ) awarded scheduled benefits for the left knee injury but declined to combine the impairments of both knees for additional benefits, as the right knee condition was not causally related to the work accident (paras 2-3, 5).
Procedural History
- Workers’ Compensation Administration: The WCJ awarded scheduled benefits for the left knee injury but denied additional benefits for the preexisting right knee impairment, finding no causal connection between the two conditions (para 1).
Parties' Submissions
- Appellant (Worker): Argued that the WCJ erred by not combining the work-related left knee impairment with the preexisting right knee impairment to award additional scheduled benefits for the right knee (paras 3, 7).
- Appellees (Employer/Insurer): Contended that the preexisting right knee impairment was unrelated to the workplace accident and did not worsen as a result of the left knee injury, making additional benefits unwarranted (paras 5, 7).
Legal Issues
- Whether the WCJ erred in refusing to combine the work-related left knee impairment with the preexisting right knee impairment to award additional scheduled benefits.
Disposition
- The Court of Appeals affirmed the WCJ’s decision, holding that the worker was not entitled to additional scheduled benefits for the preexisting right knee impairment (para 8).
Reasons
Per Garcia J. (Castillo and Vanzi JJ. concurring):
The Court held that under New Mexico’s Workers’ Compensation Act, a worker is entitled to scheduled benefits only when a preexisting condition combines with a work-related injury to cause additional impairment or disability. In this case, the worker’s preexisting right knee impairment was not causally related to the workplace accident, nor was there evidence that it worsened as a result of the left knee injury. The worker’s doctors had not evaluated the right knee after the accident, and no evidence supported a causal connection between the two conditions. Without such a connection, the worker could not recover additional scheduled benefits for the right knee impairment (paras 4-7).