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Miller v. American Airlines, Inc.

Citations: 582 A.2d 440; 1990 R.I. LEXIS 163; 1990 WL 180683Docket: No. 89-319-M.P.

Court: Supreme Court of Rhode Island; November 12, 1990; Rhode Island; State Supreme Court

Narrative Opinion Summary

In a case involving American Airlines, Inc. and an employee, the court reviewed a final decree by the Workers’ Compensation Appellate Commission regarding benefits for partial disability due to a recurrence of a back injury. The employee originally sustained the injury while working as a ticket agent, leading to total incapacity benefits. After returning to work, she suffered further recurrences, with the latest in 1987. Upon her attempt to return, the employer found her medical reports unsatisfactory. The Appellate Commission modified the trial commissioner's decree, extending compensation as it found the employee’s condition and her physician's testimony credible and uncontradicted. The court upheld the Commission's findings, asserting they were supported by legally competent evidence. It ruled that the determination of benefits was based on the loss of earning capacity, not just physical disability, and noted the employer's failure to meet the burden of proof. Consequently, the commission's decision to continue compensation was affirmed, and the petition for certiorari was denied and dismissed.

Legal Issues Addressed

Credibility Determinations in Workers' Compensation Cases

Application: The Appellate Commission was justified in its credibility assessments, accepting uncontradicted testimonies of the employee and her physician.

Reasoning: The court found that the evidence reviewed by the Appellate Commission was uncontradicted and that both the trial commissioner and the Appellate Commission accepted the employee's and her physician's testimonies without issue of credibility.

Determination of Workers' Compensation Benefits

Application: Workers’ compensation benefits were awarded based on the loss of earning capacity due to injury, not merely physical disability.

Reasoning: Workers’ compensation benefits are determined by loss of earning capacity due to an injury, not merely physical disability.

Employer's Burden in Workers' Compensation Claims

Application: The employer did not meet the burden of proof to shift liability, as the employee could not resume her job due to the employer's actions.

Reasoning: The burden of proof has not shifted to the employer. The employee in this case cannot return to her pre-1969 job due to her disability, and the employer has obstructed her ability to resume her most recent employment, which she is capable of performing.

Review of Workers' Compensation Commission Decisions

Application: The court affirmed the Appellate Commission's decision, emphasizing that findings of fact are upheld if supported by legally competent evidence.

Reasoning: The findings of fact by the Appellate Commission are upheld, provided there is legally competent evidence in the record to support them.

Standard of Review in Workers' Compensation Appeals

Application: The Appellate Commission applied a de novo standard of review appropriately, as the evidence was uncontradicted.

Reasoning: Therefore, the Appellate Commission was justified in applying a de novo standard of review.