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Karkanen v. Perini Arctic Associates

Citations: 651 P.2d 845; 1982 Alas. LEXIS 361Docket: No. 6331

Court: Alaska Supreme Court; September 24, 1982; Alaska; State Supreme Court

Narrative Opinion Summary

This case involves a dispute over workers' compensation benefits claimed by a heavy equipment operator who sustained a back injury in 1976. The claimant sought benefits for permanent partial disability, which were initially denied by the Workers' Compensation Board. The board questioned the veracity of the claimant's injury severity and dismissed corroborating medical opinions, concluding that the claimant had fully recovered without any loss in earning capacity. Upon appeal, the superior court found the evidence insufficient to entirely dismiss the existence of a physical impairment but concurred with the board's assessment regarding the absence of a wage earning capacity loss. The claimant argued that the superior court should have remanded the case to the board for further evaluation of wage earning capacity, a contention not disputed by the employer. The appellate court reversed the superior court's decision, highlighting the board's failure to adequately explore the causal link between the injury and the alleged impairment, and remanded the case for comprehensive findings on the claimant's compensable disability. Chief Justice Burke abstained from the decision.

Legal Issues Addressed

Assessment of Causation in Workers' Compensation Claims

Application: The Board must conduct a thorough inquiry into the causal connection between the injury and any impairment, which was lacking in this case.

Reasoning: The court identified a lack of inquiry by the Board concerning Karkanen's wage earning capacity, as it did not accept a causal connection between the injury and any impairment.

Responsibility for Fact-Finding

Application: The appellate court emphasized that the fact-finding responsibility lies with the Workers' Compensation Board, not the superior court, prompting a remand for further findings.

Reasoning: The ruling was reversed and remanded to the Board for proper findings on the extent of Karkanen's compensable disability, emphasizing that fact-finding is the Board's responsibility rather than the superior court's.

Standard of Review on Appeal

Application: The superior court reviewed the evidence and found insufficient evidence to negate the existence of a physical impairment but upheld the Board's finding regarding wage earning capacity.

Reasoning: On appeal, the superior court found insufficient evidence to negate the existence of a physical impairment connected to the work injury but affirmed the Board's finding that Karkanen did not suffer a loss in wage earning capacity.

Workers' Compensation and Permanent Partial Disability

Application: The Workers' Compensation Board denied benefits for permanent partial disability, concluding the claimant had fully recovered with no permanent impairment.

Reasoning: The Workers' Compensation Board denied his application, expressing skepticism about Karkanen's testimony regarding the injury's severity and dismissing the supporting medical opinion from his physician.