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

A psychiatric nurse employed at the New Mexico State Penitentiary was brutally beaten by a psychotic prisoner on November 28, 1988. The worker sustained physical injuries to her face and head, requiring intermittent medical treatment until December 1989, and developed post-traumatic stress disorder (PTSD), which persisted at the time of the hearing (paras 2-3).

Procedural History

• Workers' Compensation Administration: The workers' compensation judge found the worker to be totally temporarily disabled from the date of the accident until March 15, 1991, and totally permanently disabled due to secondary mental impairment from March 15, 1991, onward. The judge awarded 119 weeks and 4 days of total disability benefits for the secondary mental impairment and $9,000 in attorney fees (paras 3-4).

Parties' Submissions

• Employer (Appellant): Argued that the workers' compensation judge misinterpreted the law limiting compensation benefits for secondary mental impairment, lacked evidence to support her interpretation, and erred in finding sufficient evidence of total disability. Additionally, the employer challenged the admission of medical records and claimed the attorney fees awarded were excessive (para 4).
• Worker (Appellee): Contended that she was totally disabled due to her psychological state, which prevented her from performing nursing duties or maintaining continuing education in nursing. She argued that her part-time work in a different program did not negate her total disability (para 5).

Legal Issues

• Did the workers' compensation judge misinterpret the statutory provisions limiting compensation benefits for secondary mental impairment?
• Was there sufficient evidence to support the finding of total disability?
• Were the medical records properly admitted into evidence despite not being disclosed in a timely manner?
• Were the attorney fees awarded excessive?

Disposition

• The Court of Appeals reversed the workers' compensation judge's interpretation of the law regarding the duration of benefits for secondary mental impairment and remanded the case for a corrected award of compensation benefits and recalculation of attorney fees (paras 4, 14-15).
• The Court upheld the findings of total disability and the admission of medical records (para 4).

Reasons

Per Pickard J. (Minzner C.J. and Bivins J. concurring):

• The Court found that the workers' compensation judge erred in her interpretation of NMSA 1978, Section 52-1-41(A)(2), which governs the duration of compensation benefits for secondary mental impairment. The judge's interpretation would allow workers disabled by mental impairments to receive benefits for a longer period than other disabled workers, which was not the legislature's intent (paras 8-12).
• The Court adopted the employer's interpretation, holding that compensation for secondary mental impairment is limited to the greater of 100 weeks or the duration of the physical disability. The evidence did not support the judge's finding that the worker's physical impairment lasted 119 weeks and 4 days, as her last medical treatment for physical injuries occurred in December 1989 (paras 12-13).
• The Court upheld the finding of total disability, noting substantial evidence that the worker's psychological state prevented her from performing nursing duties or handling a full client base in her part-time job (para 5).
• The Court found no error in the admission of medical records, as the employer failed to demonstrate that the issue was properly raised below (para 6).
• The Court remanded the case for a determination of the maximum period allowable for the worker's physical disability and recalculation of attorney fees based on the revised award (para 14).