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Hayward v. Boh Bros. Construction Co.

Citations: 169 So. 3d 622; 14 La.App. 5 Cir. 860; 2015 La. App. LEXIS 558; 2015 WL 1393267Docket: No. 14-CA-860

Court: Louisiana Court of Appeal; March 25, 2015; Louisiana; State Appellate Court

Narrative Opinion Summary

The case involves Boh Brothers Construction Co. LLC appealing a workers' compensation judge's decision awarding benefits to an employee, John W. Hayward, III, following a back injury sustained on the job. The primary legal issues concern the causation of Hayward's injury, the imposition of penalties, and attorney fees against Boh Brothers. After a trial, the judge found that Hayward's injury was work-related, awarding him temporary total disability benefits and ordering Boh to pay medical expenses. The court imposed penalties and attorney fees, totaling $16,000, due to Boh's failure to reasonably dispute the claim. Boh appealed, arguing the lack of a causal link and disputing the penalties. The appellate court upheld the lower court's decision, affirming the compensability of Hayward's injury, the credibility of his testimony, and the justification for penalties, as Boh did not present sufficient evidence to contest the claim. The court confirmed that a causal relationship is presumed when symptoms manifest immediately after an accident, and it rejected Boh's claims of error, assigning all appeal costs to the employer.

Legal Issues Addressed

Burden of Proof in Compensation Claims

Application: The employee's testimony, corroborated by medical evidence, was sufficient to establish a work-related injury by a preponderance of the evidence.

Reasoning: In Hamilton v. Compass Grp. USA/Morrison, the appellate court upheld the workers’ compensation judge's findings, affirming that Hayward proved his work-related injury by a preponderance of the evidence.

Causation in Workers' Compensation Claims

Application: The court evaluated conflicting testimonies and determined that the employee's injury was causally related to the work incident despite the employer's contention.

Reasoning: The judge determined that Hayward sustained a compensable work-related injury, granting him temporary total disability benefits from May 13, 2013, and requiring Boh to cover medical expenses related to the injury.

Credibility of Witness Testimony

Application: The court emphasized its role in assessing witness credibility, ultimately siding with the employee's account of the incident.

Reasoning: The court emphasized its role in evaluating witness credibility amidst conflicting testimonies, ultimately finding a direct causal relationship between the work accident and Hayward's injuries.

Penalties and Attorney Fees in Workers' Compensation

Application: The workers' compensation judge imposed penalties and attorney fees on the employer for failing to reasonably controvert the employee's entitlement to benefits.

Reasoning: The appellate court affirmed this determination, concluding that Boh's refusal to pay was unjustified, and all appeal costs were assigned to Boh Brothers Construction Company, LLC.

Presumption of Work-Related Disability

Application: The court inferred a causal relationship between the work accident and the employee's disability, noting the absence of intervening causes and the manifestation of symptoms immediately post-incident.

Reasoning: A claimant's disability is presumed work-related if they were healthy prior to the accident and symptoms manifest immediately after.