Court: Appellate Court of Illinois; May 14, 1991; Illinois; State Appellate Court
Claimant Ned Wright filed for workers' compensation benefits following an injury sustained on November 4, 1987, while operating a scoop machine at Peabody Coal Company. The arbitrator awarded temporary total benefits, a decision upheld by the Industrial Commission and confirmed by the circuit court. Peabody Coal Company appeals, arguing that the Commission's finding of a causal link between Wright's injury and his employment was against the manifest weight of the evidence.
To establish causation, injuries must be shown to arise from risks associated with employment. The Commission is responsible for resolving factual disputes, drawing inferences, and deciding which medical opinions to accept. Evidence presented included Wright's work history, previous injuries, and his condition before and after the November incident. Prior to the accident, he had not lost work time due to back issues. During the incident, he struggled to enter the scoop, resulting in sharp pain in his back and leg.
After seeking medical attention, he was cleared to return to work but faced ongoing difficulties with lifting and movement, leading him to avoid heavy tasks. He experienced continuous pain, muscle spasms, and required pain medication following the injury, with his condition worsening over time. Ultimately, he stopped working entirely after an episode of pain while shoveling coal on April 22, 1988. Dr. Pflasterer, his treating physician since 1984, provided testimony regarding Wright's ongoing treatment and conditions post-injury.
On November 4, 1987, Dr. Pflasterer examined the claimant at Sparta Hospital for injuries sustained while operating a scoop machine. He identified bilateral muscle spasms in the claimant's lower back, diagnosing an acute lumbar strain and prescribing medication. Despite ongoing soreness and stiffness, Dr. Pflasterer cleared the claimant to return to work on November 11, 1987, without restrictions due to the nature of coal mine work. Subsequent examinations revealed persistent issues, including a two-plus spasm in the left lumbar area on March 4, 1988, which prevented the claimant from working until March 21, 1988. Dr. Pflasterer attributed the claimant's ongoing back problems to the initial injury, stating that later incidents, such as lifting grocery bags, only exacerbated the condition. His conclusions were based on the claimant's pain levels, physical examinations, and the claimant's history.
Dr. Michael Ralph, a board-certified orthopedic surgeon, examined the claimant on March 15 and May 20, 1988, at the request of the respondent’s insurer. He found no acute distress or involuntary muscle spasms, normal reflexes, and attributed MRI abnormalities to prior surgeries, dismissing a causal link to the November 4 injury. Dr. Ralph acknowledged his limited experience with back surgeries and noted differing interpretations of the MRI results compared to Dr. Murphy, who later performed spinal fusion on the claimant in November 1988 and identified significant herniations. Additionally, records from St. Elizabeth’s Hospital indicated the claimant’s deteriorating condition leading to surgery, including muscle spasms and reduced sensation in the right foot, further corroborating the link to the original injury. Pre-surgical X-rays revealed changes since a previous discectomy in August 1986, including narrowing of the L5, S1 inter-space.
The arbitrator concluded that there was a causal link between the November 4, 1988, accident and the claimant’s subsequent lower back issues, primarily relying on Dr. Pflasterer’s testimony. The Commission upheld this finding, determining it was not against the manifest weight of the evidence. Prior to the accident, the claimant did not report significant back pain, but post-accident, they experienced considerable pain. Dr. Pflasterer, who treated the claimant consistently before and after the incident, confirmed that the claimant’s condition was causally related to the injury, supported by objective evidence of muscle spasms noted immediately after the accident. This testimony countered Dr. Ralph’s, who only treated the claimant after the injury on two occasions, and was further weakened by Dr. Murphy’s MRI analysis and the findings in the St. Elizabeth Hospital records. The circuit court's judgment was affirmed, with judges McCullough, McNamara, Lewis, and Stouder concurring.
