Proper Weighing of Medical Evidence and Presumption of Causation in Workers’ Compensation Claims

Introduction

This commentary examines the West Virginia Supreme Court decision in Caitlin R. Workman v. ACNR Resources, Inc., handed down on June 6, 2025. The case arises from a workplace injury sustained by Ms. Workman in a coal mine when a chain-and-hook assembly snapped under tension, striking her right upper extremity. The core dispute centers on whether she had reached Maximum Medical Improvement (MMI) for her compensable injuries and whether her continuing symptoms were causally related to that accident. The parties include Ms. Workman as the petitioner and ACNR Resources, Inc. as the respondent, with the Workers’ Compensation Board of Review (“Board”) and the Intermediate Court of Appeals (“ICA”) having previously ruled in favor of the employer. The Supreme Court reversed and remanded, clarifying the factfinder’s duty to analyze and articulate why one medical opinion prevails over another and reaffirming the presumption of causation in workers’ compensation cases.

Summary of the Judgment

The Supreme Court reversed the ICA’s affirmation of the Board’s order that:

Had suspended Ms. Workman’s Temporary Total Disability (TTD) benefits as of December 16, 2021;
Denied authorization for additional medical testing and treatment;
Found she had reached MMI for the compensable conditions (right shoulder contusion and right back laceration).

The Court held that the Board violated West Virginia Code § 23-4-1g(a) by failing to meaningfully weigh and articulate why it accepted the report of an independent evaluator (Dr. Mukkamala) over three treating providers. It also ran afoul of the presumption of causation rule from Dunlap v. State Workmen’s Compensation Commissioner, Syl. Pt. 2 (1977), because there was no evidence attributing Ms. Workman’s continuing symptoms to any cause other than her industrial accident. The Court remanded with directions to award TTD benefits from November 9, 2021, through April 9, 2022, and to authorize additional testing and treatment supported by proper medical evidence.

Analysis

1. Precedents Cited

The Court relied principally on two key precedents:

Duff v. Kanawha County Commission (2024): Establishes the mixed standard of review for workers’ compensation appeals—questions of law are reviewed de novo, while factual findings are afforded deference unless clearly wrong. It also emphasizes the statutory duty under West Virginia Code § 23-4-1g(a) to weigh conflicting medical opinions for relevance, credibility, materiality, and reliability.
Dunlap v. State Workmen’s Compensation Commissioner (1977): Articulates the presumption of causation—once an injured worker offers some evidence that their injury arose from an industrial accident, and absent proof of an alternate cause, the injury is presumed compensable.

2. Legal Reasoning

The Court’s reasoning unfolded in three major steps:

Statutory Weighing Mandate
Under W. Va. Code § 23-4-1g(a), the factfinder must “weigh the conflicting medical opinions in terms of relevance, credibility, materiality and reliability.” A conclusory statement accepting one opinion without analysis violates that duty. Here, the Board simply adopted Dr. Mukkamala’s conclusion of MMI and non-causation without explaining why it rejected the opinions of Ms. Workman’s treating providers.
Presumption of Causation
Per Dunlap, once Ms. Workman presented evidence linking her symptoms—pain, grip weakness, tremor—to the industrial accident, the Board needed concrete proof of an alternate etiology to rebut that presumption. Dr. Mukkamala’s bare assertion that the symptoms were unrelated fell short of that burden.
Failure to Articulate
The Board’s order merely concluded that Ms. Workman had MMI and that her residual symptoms were not compensable, without:
- Identifying any inconsistency in the treating providers’ records;
- Explaining why Dr. Mukkamala’s methodology or findings were superior;
- Addressing the medical plausibility of new-onset tremor and weakness absent the workplace injury.

3. Impact on Future Cases

This decision imposes a stricter requirement on the Board and lower tribunals to:

Perform a transparent, point-by-point comparison of conflicting medical evidence;
Articulate reasons for crediting one physician over another in writing;
Respect the presumption of causation unless rebutted by specific, reliable evidence of an alternative cause.

Failure to do so may invite reversal and remand, ensuring fair process and protecting injured workers’ due-process rights.

Complex Concepts Simplified

Maximum Medical Improvement (MMI): The point at which an injured worker’s condition has stabilized and is not expected to improve further with additional treatment.
Temporary Total Disability (TTD) Benefits: Wage-replacement benefits paid to a worker who is medically unable to return to any form of gainful employment during recovery.
De Novo vs. Deference: De novo review means the appellate court considers legal questions afresh. Deference for findings of fact means the appellate court will uphold them unless they are “clearly wrong.”
Presumption of Causation: A legal rule that, once some evidence links an injury to an industrial accident, the injury is presumed work-related unless convincingly shown otherwise.

Conclusion

The decision in Workman v. ACNR Resources, Inc. crystallizes two fundamental principles in West Virginia workers’ compensation law: (1) the strict duty of factfinders to analyze and explain their treatment of conflicting medical opinions under W. Va. Code § 23-4-1g(a), and (2) the enduring presumption of causation for work-related injuries absent proof of an alternate cause. By reversing and remanding, the Supreme Court reasserted the procedural safeguards designed to protect injured workers’ rights to benefits and medical care. Going forward, tribunals must provide reasoned explanations when adopting or rejecting expert medical testimony and must respect the statutory presumption linking compensable accidents to subsequent injuries.