City of Jennings v. Mary Lou Doucet

CourtLouisiana Court of Appeal
DecidedFebruary 4, 2004
DocketWCA-0003-1099
StatusUnknown

This text of City of Jennings v. Mary Lou Doucet (City of Jennings v. Mary Lou Doucet) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Jennings v. Mary Lou Doucet, (La. Ct. App. 2004).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

03-1099

CITY OF JENNINGS

VERSUS

MARY LOU DOUCET

********** APPEAL FROM THE OFFICE OF WORKERS' COMPENSATION - # 3 PARISH OF CALCASIEU, NO. 01-01506 CHARLOTTE A. L. BUSHNELL, WORKERS COMPENSATION JUDGE

********** ELIZABETH A. PICKETT JUDGE

**********

Court composed of Billie Colombaro Woodard, Elizabeth A. Pickett, and Arthur J. Planchard,* Judges.

AFFIRMED AS AMENDED.

Michael Benny Miller Miller & Miller P. O. Box 1630 Crowley, LA 70527-1630 (337) 785-9500 Counsel for Defendant Appellant: Mary Lou Doucet

Lisa Eve Mayer Borne, Wilkes & Brady, LLP P. O. Box 4305 Lafayette, LA 70502-4305 (337) 232-1604 Counsel for Plaintiff Appellee: City of Jennings

* Judge Arthur J. Planchard, Retired participated in this decision by appointment of the Louisiana Supreme Court as Judge Pro Tempore. Pickett, Judge.

FACTS

Mary Lou Doucet was injured in December 1993 or January 1994 while in the

course and scope of her employment as a police officer for the City of Jennings.

The current dispute arose when the City filed a disputed claim for compensation

alleging that Doucet had failed to cooperate with court ordered vocational

rehabilitation. The WCJ appointed Thomas Bott to work with Doucet on August 20,

1998. Bott had two meetings with Doucet. Thereafter, he never met with Doucet

again but did meet with her treating physician, Dr. Olga Reaville. Bott attempted to

have Doucet complete a functional capacity evaluation (FCE) which was prescribed

by Dr. Bramlett, the claimant’s treating psychiatrist. The FCE was scheduled on

three separate occasions but was never performed because, upon advice of counsel,

Doucet refused to submit to an FCE unless it was performed at her choice of facilities.

In November, 2001, Dr. Bramlett determined he could outline Doucet’s capabilities

without the FCE.

Using the guidelines outlined by Dr. Bramlett, Bott attempted to find suitable

employment for Doucet in the Lake Charles area. On February 27, 2002, he presented

the job descriptions to Dr. Bramlett who approved some of the jobs and rejected

others. At this time, however, Doucet was hospitalized because she had attempted

suicide and was unable to work.

On March 21, 2002, Bott sent a letter to Doucet with a list of the jobs and their

descriptions, instructions on how to proceed, and an offer to help her locate a suitable

job. On March 27, 2002, Bott again met with Dr. Bramlett with a different set of jobs

that were then available. Dr. Bramlett approved one, rejected three, and required

additional information on two others. Dr. Reaville disapproved all of the jobs

1 presented with the exception of one, which had been rejected by Dr. Bramlett. Bott

later discovered the claimant had actually applied for three of the positions but moved

to Washington before knowing whether she would be hired.

After a trial on the merits, the worker’s compensation judge (WCJ) determined

the issue regarding the failure to cooperate with the vocational rehabilitation counselor

was moot. Further, she found Doucet capable of working 20 hours a week at minimum

wage and reduced her benefits accordingly. This appeal followed.

ASSIGMENTS OF ERROR

Mary Lou Doucet appeals, alleging one assignment of error:

1) The hearing officer erred in reducing Ms. Doucet’s weekly compensation benefits.

Answering the appeal, the City of Jennings alleges four assignments of error:

1) That the trial court failed to reduce plaintiff’s benefits by 50% for failing to cooperate with vocational rehabilitation efforts.

2) That the trial court failed to find that the claimant was capable of working at least thirty hours per week.

3) That the trial court failed to state the dollar amount of wages the claimant was capable of earning.

4) That the trial court was incorrect in assessing the costs to be paid by employer/appellee, the City of Jeannings.

DISCUSSION

We will first address the City’s first assignment of error wherein they argue the

WCJ erred by not reducing the claimant’s benefits by 50% for her failure to cooperate

with the vocational rehabilitation efforts.

Louisiana Revised Statute 23:1226(E) states in pertinent part (emphasis added):

Refusal to accept rehabilitation as deemed necessary by the workers’ compensation judge shall result in a fifty percent reduction in weekly compensation, including supplemental

2 earnings benefits pursuant to R.S. 23:1221(3), for each week of the period of refusal.

This statute is penal in nature and penal statutes are strictly construed. Fontenot

v. Reddell Vidrine Water Dist., 02-439 (La. 1/14/03), 836 So.2d 14.

The basis of this complaint is Doucet’s refusal to submit to an FCE. She

refused on the advise of her attorney, claiming she had the right to choose the facility

which would perform the FCE.

Following the trial the WCJ found the following facts: 1) The claimant had

been previously ordered to comply with vocational rehabilitation counseling with

Thomas Bott; 2) the claimant’s treating psychiatrist, Dr. Bramlett, issued a

prescription for the FCE which was set up to be performed at the Fontana Center; 3)

The FCE was never performed as the claimant did not attend. The WCJ further found,

and concluded, that Dr. Bramlett was able to issue work restrictions without the FCE

and, therefore, the FCE was not needed.

Louisiana Revised Statute 23:1226(E) only provides penalties for refusing to

accept rehabilitation “as deemed necessary by the workers’ compensation judge.”

Since the WCJ concluded the FCE was not “necessary,” she declined to impose the

penalty. We find no error in her conclusion on her denial of the employer’s request

for imposition of the penalty provided in 23:1226(E). This assignment of error is

without merit.

Doucet’s assignment of error and the City’s second and third assignments of

error will be discussed together as they are interrelated.

Doucet argues the WCJ erred in finding she was capable of returning to work

part time and reducing her benefits accordingly. The City argues, to the contrary, that

the WCJ erred by not finding the claimant capable of working thirty hours a week, and

3 at a rate higher than minimum wage. These issues involve factual findings subject to

reversal only if we find the WCJ was clearly wrong or manifestly erroneous. Smith

v. La. Dept. of Corrections, 93-1305 (La. 2/28/94), 633 So.2d 129.

[A]n employer may discharge its burden of proving job availability by establishing, at a minimum, the following, by competent evidence:

(1) the existence of a suitable job within claimant’s physical capabilities and within claimant’s or the employer’s community or reasonable geographic region:

(2) the amount of wages that an employee with claimant’s experience and training can be expected to earn in that job; and

(3) an actual position available for that particular job at the time that the claimant received notification of the job’s existence.

By “suitable job,” we mean a job that claimant is not only physically capable of performing, but one that also falls within the limits of claimant’s age, experience, and education, unless, of course, the employer or potential employer is willing to provide any additional necessary training or education.

Banks v. Indus. Roofing and Sheet Metal Works, Inc., 96-2840, p.10-11 (La. 7/1/97),

696 So.2d 551, 557.

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Related

Smith v. Louisiana Dept. of Corrections
633 So. 2d 129 (Supreme Court of Louisiana, 1994)
Wiley v. Grand Casino Avoyelles
731 So. 2d 518 (Louisiana Court of Appeal, 1999)
Sharbono v. H & S CONST. CO.
478 So. 2d 779 (Louisiana Court of Appeal, 1985)
Fontenot v. Reddell Vidrine Water Dist.
836 So. 2d 14 (Supreme Court of Louisiana, 2003)

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City of Jennings v. Mary Lou Doucet, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-jennings-v-mary-lou-doucet-lactapp-2004.