Background
Terri Sparks, a test proctor for North Arkansas College, injured her right ankle when she tripped on a mat and fell while entering the college library in January 2022. She previously had undergone ankle surgery in 2020, but she testified that she recovered, returned to work, and sought no further ankle treatment before the workplace fall, although the ankle still bothered her somewhat.
After the fall, Sparks experienced persistent pain and difficulty bearing weight. Her former surgeon, Dr. Jason Pleimann, attributed none of the postinjury MRI pathology to the workplace accident and concluded that she had reached maximum medical improvement with no permanent impairment. A new physician, Dr. Kevin Steffen, reviewed imaging from before and after the fall, diagnosed posttraumatic arthritis, and performed ankle surgery in September 2023. An administrative law judge found the surgery attributable to Sparks’s preexisting degenerative condition, but the Workers’ Compensation Commission reversed and awarded the additional treatment.
The Court’s Holding
The Arkansas Court of Appeals affirmed, holding that substantial evidence supported the Commission’s finding that Sparks’s surgery was reasonably necessary in connection with her compensable injury. A claimant seeking additional medical treatment need not prove that the compensable injury was the major cause of the treatment; the claimant need show only that the injury was a factor in the need for treatment.
The Commission did not arbitrarily disregard Dr. Pleimann’s causation opinion. It acknowledged that opinion but assigned it minimal weight in light of other evidence, including postinjury imaging showing a split tear of the peroneal brevis tendon that was absent from earlier imaging, Dr. Steffen’s description of posttraumatic arthritis and significant bone-marrow edema, and Sparks’s testimony that her symptoms substantially worsened after the fall. Even if the surgery principally treated degenerative conditions rather than the tendon tear, the Commission reasonably could find that the workplace injury aggravated the preexisting condition and contributed to the need for surgery.
Key Takeaways
- A claimant seeking additional medical treatment must establish that the compensable injury was a factor in the need for treatment, not its major cause.
- An employer takes an employee as it finds her, and a compensable injury’s aggravation of a preexisting condition may itself be compensable.
- The Commission may weigh conflicting medical opinions, and an appellate court will affirm when substantial evidence permits reasonable minds to reach the Commission’s conclusion.
Why It Matters
The decision confirms that degenerative or preexisting conditions do not necessarily relieve an employer of responsibility for medical treatment after a workplace injury. When credible testimony, medical evidence, and postinjury imaging show that a compensable event worsened the employee’s condition and contributed to the need for treatment, the Commission may award that treatment even when another physician disputes causation.