Grady v. Mohegan Tribal Gaming Authority

10 Am. Tribal Law 181
CourtMohegan Gaming Disputes Trial Court
DecidedJune 18, 2010
DocketNo. GDTC-WC-09-125-FAM
StatusPublished
Cited by1 cases

This text of 10 Am. Tribal Law 181 (Grady v. Mohegan Tribal Gaming Authority) is published on Counsel Stack Legal Research, covering Mohegan Gaming Disputes Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Grady v. Mohegan Tribal Gaming Authority, 10 Am. Tribal Law 181 (Mo. 2010).

Opinion

MEMORANDUM OF DECISION

MANFREDI, J.

This is an appeal of a decision of the Mohegan Tribal Workers’ Compensation Commission rendered on June 4, 2009. The appeal is taken pursuant to MTC Section 4-207. This court’s decision is rendered pursuant to MTC Section 4—207(j) and raises an issue of first impression with this court.

ISSUES

The appellant has raised four issues in its brief:

I. STARE DECISIS

“Stare Decisis is not a rule of law, but a matter of judicial policy.” 20 AmJur. 2d 520, Courts, Sec. 184.

In fact, the doctrine of stare decisis tells us that courts exercising lower jurisdiction must accept the law as set forth by decisions of a court of higher jurisdiction; White v. Burns, 213 Conn. 307, 335, 567 A.2d 1195 (1990) and decisions of one trial court are not binding upon another. Housing Authority of Enfield v. Rusotto, 2006 WL 76391 (Conn.Super.2006). The doctrine does not apply to decisions of Workers’ Compensation Commissioners except to the extent that such decisions should be given due deference when dealing with similar issues.

Here, Commissioner Pacelli was under no legal constraint to rule in a manner identical to his ruling in Giansanti v. MTGA, and moreover, an analysis of that case reveals sufficient factual differences such that it is readily distinguishable from the case at hand. In Gianscmti the Commissioner awarded full benefits but the number of weeks of disability payments [183]*183were reduced by a percentage based upon specific medical findings. Here the Commissioner awarded full benefits to Mr. Grady for the period of time his disability was attributed to his present injury as there was no medical evidence which indicated the period of disability was caused by any other condition. The Commissioner did not err by following a different course here than that taken in Giansanti.

II. LEGISLATIVE INTENT

In connection with the appellant’s claim that the commissioner abused his discretion regarding- the intention of the tribe’s risk management policy, this court notes that there is simply no evidence at all in the record regarding the legislative history surrounding the Mohegan Workers’ Compensation Act.

This Court declines to speculate regarding “legislative intent” and will not overturn the Commissioner’s decision based upon mere speculation.

III. CLAIMANT’S MEDICAL TREATMENT ENDED ON 12-18-08

Appellant also claims the Commissioner erred by determining that Mr. Grady’s medical treatment for this injury terminated on December 18, 2008.

Mohegan Tribe Code Section 4-207(g) states:

“The Mohegan Court shall not substitute its judgment for that of the Mohegan Workers’ Compensation Commission as to the weight of the evidence on questions of fact.”

As set out in the findings, the claimant treated with Dr. Pasha from July 17, 2008 and continued to see him until and through December 18, 2008 when Dr. Pasha turned the treatment over to Dr. West of the Veteran’s Administration. (Findings, lb-24). There is ample evidence in Dr. Pasha’s notes to support these findings, and the Court may not substitute its judgment for the Commissioner’s even if it disagreed.

Furthermore, the Respondent’s own “Revised Motion to Correct Finding” dated June 26, 2009 requested the Commissioner to add the following to his findings:

“The Claimant was totally disabled from work at Respondent-Employer Mohegan Sun Casino from 06/08/08 to 12/18/08.”

Clearly, Respondent’s position based on its Motion to Correct is that Claimant was totally disabled at least through December 18, 2008 when he last saw Dr. Pasha. The medical evidence in the record clearly supports the Commissioner’s findings and conclusions that Mr. Grady was totally disabled as a result of this injury through December 18, 2008.

IV.APPORTIONMENT

The crux of the appellant’s argument appears to be that because the claimant had a service related disability from his military service, any compensation he received following the work related injury of June 8, 2008 should be reduced by the percentage of that disability including any payment for temporary total disability. This argument is based upon the appellant’s interpretation of MTC 4-171(3). That statute reads that:

“For aggravation of a pre-existing injury or occupational disease, compensation shall be allowed only for that proportion of the disability or death due to the aggravation of the pre-existing injury or occupational disease as may be reasonably attributed to the injury upon which the claim is based.”

Although the Mohegan Workers’ Compensation Code defines the term “previous disability” it does not define the term “disability”. As noted in the American Medi[184]*184cal Association Guide to the Evaluation of Permanent Impairment, Fourth Edition:

“Disability may be defined as an alteration of an individual’s capacity to meet personal, social, or occupational demands, or statutory or regulatory requirements, because of an impairment. Disability refers to an activity or task the individual cannot accomplish.”

Here, although the claimant may have been suffering from a previous disability, as defined by the code, he was not “disabled” from performing the tasks of his occupation at the time of his injury in June of 2008, other than missing a few days of work per month. In all other respects he essentially worked full time performing the requirements of his occupation.

As Commissioner Pacelli noted:

“Claimant’s payroll records indicate that in the year prior to June 8, 2008 he averaged seven days a month of lost time from work due to chronic pain. However, he rarely lost more than a few consecutive days in a row. Only twice in this time period did he lose more than seven consecutive days or work due to chronic pain. Claimant always returned to unrestricted, full duty when he returned to work.” Commissioner's Finding of Fact and Award Number 8.

The Commissioner’s Conclusion in Paragraph E stated:

“As a result of the aforesaid, during the years that the claimant worked for the Mohegan Sun, he found it necessary to regularly take approximately 4-7 days per month of unpaid medical leave from his job due to flair ups of his back and/or neck. This medical leave rarely required him to miss more than a few days of work at a time. Additionally, when the claimant returned to work, he did so to full duty without restrictions. As this medical leave was unpaid and resulted in reduced earnings, the claimant’s compensation rate already reflects this loss of income. Thus, if a prior disability to the claimant’s back or neck can be sufficiently established, any proportionate reduction in compensation benefits due should only occur from PPD Benefits (Section 4—232(d)) not TTD Benefits (Section 4-230).”

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Related

Santoro v. Mohegan Tribal Gaming Authority
12 Am. Tribal Law 398 (Mohegan Gaming Disputes Trial Court, 2012)

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Bluebook (online)
10 Am. Tribal Law 181, Counsel Stack Legal Research, https://law.counselstack.com/opinion/grady-v-mohegan-tribal-gaming-authority-mohegangct-2010.