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Malbrew v. Port Barre Mills, Inc.

Citations: 693 So. 2d 259; 96 La.App. 3 Cir. 790; 1997 La. App. LEXIS 1111; 1997 WL 196643Docket: No. 96-790

Court: Louisiana Court of Appeal; April 23, 1997; Louisiana; State Appellate Court

Narrative Opinion Summary

In this workers' compensation case, the claimant alleged a temporary total disability stemming from a mental injury related to a physical injury sustained while employed. The employer initially provided benefits but terminated them after receiving medical reports. Upon the claimant's rejection of a modified job offer, benefits were temporarily reinstated until the trial. The hearing officer dismissed the claimant's case, citing insufficient evidence of a physical injury and mental injury causation. The court referenced La.R.S. 23:1021(7)(e), emphasizing the need for clear and convincing evidence to establish a compensable mental injury related to a physical injury. The claimant's appeal argued the officer erred in determining no physical injury, but medical testimonies supported this conclusion. Consequently, the officer's decision to terminate benefits was upheld. However, the judgment awarded the claimant $181.44 for medical mileage expenses, acknowledged without objection, and apportioned appeal costs equally between the parties. The judgment was affirmed with amendments, notwithstanding the dissent of two judges.

Legal Issues Addressed

Award of Medical Mileage Expenses

Application: The defendant conceded the plaintiff was entitled to compensation for medical mileage expenses presented at trial.

Reasoning: The defendant acknowledged the plaintiff's entitlement to $181.44 for medical mileage expenses, which were presented during the trial without objection.

Burden of Proof in Workers' Compensation Claims

Application: The plaintiff did not satisfy the burden of proof as the evidence did not meet the requisite standard to establish a physical injury.

Reasoning: The evidence did not meet the clear and convincing standard required under La.R.S. 23:1021(7)(c) to prove entitlement to benefits, leading to a conclusion that there was no manifest error in the hearing officer’s determination that the plaintiff did not sustain a physical injury.

Compensation for Mental Injury under La.R.S. 23:1021(7)(e)

Application: The court applied the standard requiring clear and convincing evidence to prove a mental injury resulting from a physical injury, which the plaintiff failed to meet.

Reasoning: Under La.R.S. 23:1021(7)(e), a mental injury resulting from a physical injury is not compensable unless proven by clear and convincing evidence.

Termination of Total Temporary Disability Benefits

Application: The termination of benefits was justified based on medical evaluations indicating no ongoing physical disability.

Reasoning: The hearing officer determined the defendant was justified in terminating benefits and did not award medical mileage expenses.