Background
Jack Crampton worked at a sawmill through staffing agency Express Services, handling heavy boards as part of the daily processing of approximately 6,000 boards. On September 20, 2024, Crampton completed his shift without reporting any symptoms. That night, he woke with numbness and pain radiating down his left arm and hand. He did not seek medical attention until October 1, 2024, when he presented to Rainelle Medical Center reporting severe pain in his left arm, radiating to his hand, with burning and numbness.
On October 10, 2024, Crampton filed a workers’ compensation claim, alleging he injured his left arm and hand on September 20 while pulling boards. However, physician assistant PA-C Stephanie Hamilton stated in the claim form that Crampton’s left shoulder condition was a direct result of non-occupational causes, including degenerative disease, and that there was no work injury. The claim administrator initially denied it, then inexplicably approved it on December 19, 2024, finding the injury compensable. On March 24, 2025, the administrator issued a corrected order denying the claim, stating the prior approval was a “mistake or clerical error.” The Workers’ Compensation Board of Review affirmed the denial.
In his deposition, Crampton testified that he suffered no symptoms when leaving work on September 20, only developing numbness and pain after arriving home that evening. He did not point to any single traumatic event but alleged the injury resulted from repetitive board-pulling actions. Medical imaging revealed degenerative changes and a small rotator cuff tear. Dr. Austin Nabet opined the injury was work-related, but his opinion assumed symptoms had begun at work—contradicting Crampton’s own testimony.
The Court’s Holding
The Intermediate Court of Appeals affirmed the Board’s denial. Applying West Virginia’s three-element test for workers’ compensation, the court found Crampton failed to establish all requirements: (1) a personal injury, (2) received in the course of employment, and (3) resulting from that employment. The court noted that to establish compensability, an employee must show by competent evidence a causal connection between the disability and employment.
The court rejected Crampton’s claim based on several factors. First, PA-C Hamilton had concluded the shoulder condition was non-occupational and degenerative. Second, no medical provider opined that repetitive workplace actions caused his conditions—Dr. Nabet’s report was found unreliable because it was predicated on the factually incorrect assumption that symptoms began while Crampton was at work, when his own testimony placed symptom onset after leaving work. Third, Crampton’s initial statement to medical providers that there was no work injury undermined his later contrary assertion.
The court applied the highly deferential “clearly wrong” standard of review, which presumes agency decisions valid when supported by substantial evidence or a rational basis. Under this standard, the court concluded the Board was not clearly wrong in finding that preponderance of the evidence did not support work causation. The court also dismissed as moot Crampton’s protests regarding denial of a specialist referral and overpayment of temporary total disability benefits, since no compensable injury was established.
Key Takeaways
- West Virginia requires employees to prove three elements for compensability: personal injury, incurred during employment, and caused by employment; failure on any element defeats the claim.
- Medical expert opinion regarding causation is critical; absent testimony linking workplace activity to the injury, claims fail even when injury develops shortly after work.
- Medical expert opinions can be discredited or deemed unreliable when based on factually incorrect premises, such as incorrect timing of symptom onset.
- Initial statements to medical providers denying a work connection can weigh heavily against later claims of workplace causation.
- Courts apply a highly deferential standard when reviewing Workers’ Compensation Board decisions, affirming them when supported by substantial evidence.
Why It Matters
This decision reinforces the substantial evidentiary burden employees face when establishing work-related injuries in West Virginia workers’ compensation claims. Crampton presents a cautionary scenario: despite working in a physically demanding job and developing upper extremity injuries shortly after performing labor-intensive tasks, the absence of clear medical testimony attributing the injury to workplace activity proved dispositive. The opinion demonstrates that medical expert opinions will be closely scrutinized, particularly when they rest on factual assumptions contradicted by deposition testimony or when initial medical assessments identify non-occupational causes.
The decision also illustrates a procedural risk in the West Virginia system: the claim administrator’s unexplained reversal from approval to denial—attributed to “mistake or clerical error”—was upheld by the Board and not disturbed on appeal. For practitioners, the case underscores the critical importance of securing medical testimony that explicitly addresses causation and is grounded in accurate factual predicates, and the need to establish work-injury causation contemporaneously, before initial medical assessments attributing injury to non-occupational causes become part of the record.