Maryville R-II School District v. Daniel Payton

516 S.W.3d 874 (Mo. App. W.D. 2017)
Full Opinion: [Maryville R-II School District v. Daniel Payton]

Claimant was the Assistant Supervisor of Building and Grounds for the Maryville School District.  He had several pre-existing injuries including a left knee scope, right knee scope, and right rotator cuff surgery. His primary injury here developed over a series of events, but the most severe was Claimant hearing a pop and experiencing severe pain in his left shoulder while lifting a soccer goal. He underwent surgery for a full rotator cuff tear and then re-tore his shoulder, but chose not to undergo a second surgery. 

Commission Decision:

The ALJ in this case found that the claimant was permanently and totally disabled entirely due to the workplace injury. Because of this, it was unimportant that the claimant may have suffered prior injuries and the employer was found responsible for the entire award. The Commission affirmed this decision in its entirety.

Analysis/Holding:

This case centered on the credibility of the claimant’s witnesses and his expert’s opinion that the claimant was PTD from the left shoulder injury alone. He had no pre-existing injury to his left should and, after the injury, was unable to lift at all with his left arm and needed to recline and take naps throughout the day.

For these reasons, the Court of Appeals affirmed the ALJ and Commission decisions. 

The Takeaway:

If a claimant is found to be rendered PTD due to an injury alone, then prior injuries are irrelevant and the employer will likely be responsible for the entire award.