Narrative Opinion Summary
The case involves a petition for certiorari filed by an employee, challenging the denial of his workers' compensation benefits by the Appellate Division of the Workers’ Compensation Court. The employee initially received benefits for a back injury sustained while working for his former employer, but these were suspended after a consent decree declared his ability to return to full-time work. Subsequently, while employed elsewhere, he incurred another back injury and claimed it as a recurrence of his original incapacity. The central legal question was whether the appellate division erred by imposing a requirement on the employee to demonstrate a comparative change of condition to prove his recurrence of incapacity, contrary to G.L. 1956, § 28-33-20.1(b). The court found the appellate division's findings ambiguous and inconsistent with statutory provisions, leading to a quash of the decree and a remand for further proceedings to evaluate the employee’s incapacity without the contested evidence requirement. The ruling ensures that either party may seek additional review following the appellate division's new determination. Notably, two justices did not participate in this decision.
Legal Issues Addressed
Judicial Review and Ambiguity in Appellate Findingssubscribe to see similar legal issues
Application: The court found the appellate division's findings ambiguous when they referenced a requirement for proof of change, which contradicted the statutory mandates.
Reasoning: The appellate division's findings were deemed ambiguous as they referenced a requirement for proof of change, conflicting with the statutory mandate that does not necessitate such evidence.
Remand for Determination of Incapacitysubscribe to see similar legal issues
Application: The case was remanded to the Appellate Division to determine if Reynolds proved his incapacity to work without requiring comparative evidence of change.
Reasoning: The court remanded the case back to the Appellate Division with instructions to determine if Reynolds proved his incapacity to work for the specified periods without requiring comparative evidence.
Workers' Compensation and Recurrence of Incapacitysubscribe to see similar legal issues
Application: The court held that an employee claiming a recurrence of incapacity is not required to demonstrate a comparative change of condition under G.L. 1956, § 28-33-20.1(b).
Reasoning: The primary issue was whether the appellate division erred in requiring Reynolds to document a comparative change of condition to prove his recurrence of incapacity, despite G.L. 1956, § 28-33-20.1(b), which relieves employees of this burden in recurrence cases.