Arch Coal, Inc. v. Jobie Howard

CourtWest Virginia Supreme Court
DecidedApril 16, 2025
Docket23-391
StatusPublished

This text of Arch Coal, Inc. v. Jobie Howard (Arch Coal, Inc. v. Jobie Howard) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arch Coal, Inc. v. Jobie Howard, (W. Va. 2025).

Opinion

IN THE SUPREME COURT OF APPEALS OF WEST VIRGINIA

FILED January 2025 Term April 16, 2025 released at 3:00 p.m. C. CASEY FORBES, CLERK SUPREME COURT OF APPEALS No. 23-391 OF WEST VIRGINIA

ARCH COAL, INC., Petitioner,

v.

JOBIE HOWARD, Respondent.

Appeal from the Intermediate Court of Appeals of West Virginia Case No. 22-ICA-310

AFFIRMED

Submitted: January 29, 2025 Filed: April 16, 2025

T. Jonathan Cook, Esq. Edward Garfield Atkins, Esq. Cipriani & Werner, PC Charleston, West Virginia Charleston, West Virginia Counsel for Respondent Counsel for Petitioner

JUSTICE WALKER delivered the Opinion of the Court. SYLLABUS BY THE COURT

1. “On appeal of a decision of the West Virginia Workers’

Compensation Board of Review from the Intermediate Court of Appeals of West Virginia

to the Supreme Court of Appeals of West Virginia, the Supreme Court of Appeals is bound

by the statutory standards contained in West Virginia Code § 23-5-12a(b) (eff. Jan. 13,

2022). Questions of law are reviewed de novo, while findings of fact made by the Board

of Review are accorded deference unless the reviewing court believes the findings to be

clearly wrong.” Syllabus Point 3, Duff v. Kanawha Cnty. Comm’n, 250 W. Va. 510, 905

S.E.2d 528 (2024).

i WALKER, Justice:

Jobie Howard was severely injured while working as an electrician for Arch

Coal, Inc. In November 2022, the Workers’ Compensation Board of Review determined

that he met the whole person impairment threshold of 50% to be considered for a permanent

total disability award under West Virginia Code § 23-4-6(n)(1) (2005). The Board weighed

the medical evidence, rejected some reports as unreliable, selected the impairment ratings

from two physicians who practice in different fields of medicine and rated different body

parts, and applied the Combined Values Chart from the American Medical Association,

Guides to the Evaluation of Permanent Impairment, 322-24 (4th ed. 1993). The

Intermediate Court of Appeals affirmed, concluding that it was reasonable to combine the

physicians’ assessments to determine WPI.1 Arch Coal appeals, arguing that the ICA erred

by concluding that the factfinder had authority to substitute its own calculation of WPI for

that of a calculation performed by a physician. For the reasons explained below, we affirm.

I. FACTUAL AND PROCEDURAL BACKGROUND

On May 12, 2010, Jobie Howard suffered a career-ending injury due to an

electrical explosion while working as an electrician for Arch Coal, Inc. He was transferred

from the scene by air ambulance to Cabell Huntington Hospital, located in Huntington,

where he was hospitalized with multiple second and third-degree burns across his face,

1 Arch Coal, Inc. v. Howard, No. 22-ICA-310, 2023 WL 3172051, at *4 (W. Va. Ct. App. May 1, 2023) (memorandum decision).

1 neck, arms, and back. Mr. Howard was placed on a ventilator and underwent multiple

surgical procedures including skin grafts. While in the hospital, the trauma triggered a

herpes simplex infection in his right eye, which contributed to his physical injury to that

eye. He also has extensive symptomatic scarring, numbness and tingling in his left hand,

and multiple range of motion abnormalities in his left arm and hand.

Mr. Howard received a total of 57% in permanent partial disability awards

in this claim. He applied for a permanent total disability award in 2015. The issue on

appeal is whether Mr. Howard meets the statutory threshold of 50% WPI to be considered

for a PTD award under West Virginia Code § 23-4-6(n)(1).2 We note that awards of PTD

2 See W. Va. Code § 23-4-6(n)(1) (“Other than for those injuries specified in subdivision (m) of this section, in order to be eligible to apply for an award of permanent total disability benefits for all injuries incurred and all diseases, including occupational pneumoconiosis, regardless of the date of last exposure, on and after the effective date of the amendment and reenactment of this section during the year two thousand three, a claimant: (A) Must have been awarded the sum of fifty percent in prior permanent partial disability awards; (B) must have suffered a single occupational injury or disease which results in a finding by the commission that the claimant has suffered a medical impairment of fifty percent; or (C) has sustained a thirty-five percent statutory disability pursuant to the provisions of subdivision (f) of this section. Upon filing an application, the claim will be reevaluated by the examining board or other reviewing body pursuant to subdivision (i) of this section to determine if the claimant has suffered a whole body medical impairment of fifty percent or more resulting from either a single occupational injury or occupational disease or a combination of occupational injuries and occupational diseases or has sustained a thirty-five percent statutory disability pursuant to the provisions of subdivision (f) of this section. A claimant whose prior permanent partial disability awards total eighty- five percent or more shall also be examined by the board or other reviewing body and must be found to have suffered a whole body medical impairment of fifty percent in order for his or her request to be eligible for further review. The examining board or other reviewing body shall review the claim as provided for in subdivision (j) of this section. If the claimant has not suffered whole body medical impairment of at least fifty percent or has sustained a (continued . . .) 2 and PPD serve distinct purposes. As one court explained, PTD award payments “are wage

replacement benefits meant to compensate the worker for the permanent loss of wage-

earning capacity where the worker is unable to find work on the regular labor market.”3

On the other hand, the purpose of a PPD award “is to compensate a worker for the loss or

impairment of a physical or mental function.”4

In October 2020, the claim administrator denied Mr. Howard’s application

for PTD based on the recommendation of the PTD Review Board. Mr. Howard protested

this order, and the matter proceeded to the Board of Review for factual development.

This case is medically complex for several reasons. First, Mr. Howard

injured multiple areas of his body in the May 12, 2010, electrical explosion. He has visual

impairment and ongoing symptoms related to the physical injury of his right eye caused by

thirty-five percent statutory disability pursuant to the provisions of subdivision (f) of this section, the request shall be denied. Upon a finding that the claimant has a fifty percent whole body medical impairment or has sustained a thirty-five percent statutory disability pursuant to the provisions of subdivision (f) of this section, the review of the application continues as provided for in the following paragraph of this subdivision. Those claimants whose prior permanent partial disability awards total eighty-five percent or more and who have been found to have a whole body medical impairment of at least fifty percent or have sustained a thirty-five percent statutory disability pursuant to the provisions of subdivision (f) of this section are entitled to the rebuttable presumption created pursuant to subdivision (d) of this section for the remaining issues in the request.”). 3 Ihara v. State Dep’t of Land & Nat. Res., 404 P.3d 302, 308 (Haw. 2017) (citation omitted). 4 Id.

3 corneal scarring. The compensable injury also left him with significant orthopedic and

dermatological impairment. But even before this compensable injury occurred, Mr.

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