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Workers Compensation

Wyoming Supreme Court
Uncategorized

McDonald v. State — Wyoming Supreme Court Upholds Denial of Workers’ Compensation Benefits for Depakote-Induced Pancreatitis

The Wyoming Supreme Court affirmed the Medical Commission’s denial of workers’ compensation benefits to a claimant who developed pancreatitis after a Depakote dosage increase prescribed for migraines caused by his 2014 compensable head injury, holding that a numerical majority of supporting experts does not satisfy the preponderance-of-the-evidence standard and that the Commission acted within its discretion in rejecting an expert’s causation opinion premised on a dosing timeline contradicted by the claimant’s own testimony.

Wyoming Supreme Court
Uncategorized

Courtney v. Meyer — Safety Rule Violations Without Particularized Knowledge of Harm Do Not Establish Co-Employee Willful and Wanton Misconduct

The Wyoming Supreme Court affirmed summary judgment for a garbage-truck co-employee whose activation of lift arms—from the passenger seat, without seeing where his injured colleague was standing—caused serious hand injuries, holding that multiple safety-rule violations and a poor post-accident response do not establish the particularized knowledge of highly probable harm required to pierce co-employee immunity under the Wyoming Worker’s Compensation Act.

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