Kentucky Retirement Systems v. Ronald Ashcraft

CourtKentucky Supreme Court
DecidedNovember 1, 2018
Docket2017-SC-0345
StatusUnpublished

This text of Kentucky Retirement Systems v. Ronald Ashcraft (Kentucky Retirement Systems v. Ronald Ashcraft) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kentucky Retirement Systems v. Ronald Ashcraft, (Ky. 2018).

Opinion

RENDERED: NOVEMBER 1, 2018 TO BE PUBLISHED

2017-SC-000345-DG

KENTUCKY RETIREMENT SYSTEMS APPELLANT

ON REVIEW FROM COURT OF APPEALS V. CASE NO. 2016-CA-000114-MR FRANKLIN CIRCUIT COURT NO. 14-CI-00498

RONALD ASHCRAFT APPELLEE

OPINION OF THE COURT BY JUSTICE HUGHES

REVERSING

An incapacitated member of the Kentucky Retirement Systems (KERS) 1

may apply for disability retirement pursuant to Kentucky Revised Statute (KRS)

61.600. If the statutorily-created medical review panel recommends that the

member’s disability retirement application be denied, the applicant may then

request a formal hearing before a hearing officer who will issue a recommended

order to the KERS Board of Trustees, the administrative body charged with

making the final decision. This case, initially brought by Ronald Ashcraft, a

former employee of the Grant County Board of Education,2 presents an oft-

1 We use the initials KERS rather than KRS to avoid confusion with initials used to designate the Kentucky Revised Statutes. 2 Ashcraft was a member of the County Employees Retirement System (CERS), which is administered by the Board of Trustees of the Kentucky Retirement Systems. KRS 78.780(1). Although CERS is created through KRS Chapter 78, KRS 78.545 specifically refers to and incorporates a number of administrative matters from KRS recurring issue regarding the role of the courts on judicial review of KERS’s

final decision as to a member’s entitlement to disability retirement. KRS

61.665(5). Having concluded that the Court of Appeals’ disposition of this case

is not consistent with the controlling statute and our stated standard of review

for disability retirement matters, we re verse. 3

RELEVANT FACTS

In September 2000, Ashcraft became a member of the County Employees

Retirement System, which is administered by KERS. The Grant County Board

of Education employed Ashcraft as an HVAC technician, a position classified as

“medium work.”4 As an HVAC technician, Ashcraft was responsible for

maintaining the HVAC systems in Grant County schools and carrying all tools

required to repair and install equipment. On August 1, 2011, Ashcraft

sustained a work-related injury to his neck, upper back, and shoulders when a

29-pound vacuum pump fell from above and struck him between the shoulder

blades.

In September 2011, Ashcraft was diagnosed with cervical and lumbar

strain and with tension headaches from muscle contractions. After seeking

Chapter 61, such as disability retirement conditions, medical examinations, and hearing procedures. KRS 78.545(10)-(14), (22); see also KRS 78.780(1) requiring the Board to “cany out the provisions of KRS 78.510 to 78.852 in the same manner in which it administers the Kentucky Employees Retirement System[].” 3 Another opinion issued today, Bradley v. Kentucky Retirement Systems, 2017- SC-000275-DG, also addresses the judicial review standard in KERS disability retirement cases. 4 See KRS 61.600(5)(c), which sets forth the standards for physical exertion requirements. treatment, Ashcraft was initially given work activity restrictions on lifting and

pulling. He was also placed on light and modified duty at work.

Ashcraft filed for disability benefits on June 8, 2012, and his application

was denied by a majority of the review panel on August 24, 2012. The

reviewing physicians noted a lack of objective medical evidence in the record.

Ashcraft again applied for disability benefits and supplemented the record with

a workers’ compensation examination performed by Dr. Vaughn on August 30,

2012. Dr. Vaughn reported his objective findings of pain in the cervical and

lumbar areas, but that the findings were due to degenerative changes

compatible with Ashcraft’s age. Dr. Vaughn believed that Ashcraft could return

to work with a 50-pound lifting restriction and that Ashcraft’s total impairment

was 10 percent, due to his cervical and lumbar impairments. Ashcraft also

tendered evidence from his orthopedist, indicating this physician placed him on

light duties without strenuous exertion, and the opinion of another physician

who stated that Ashcraft could not return to his previously-held position. The

medical review panel eventually denied his second application for benefits in a

2-1 decision rendered December 19, 2012.

Meanwhile, even though Ashcraft was permitted to perform modified

duty for some time, he was ultimately taken off work by one of his physicians.

After exhausting his Family and Medical Leave Act (FMLA) time and sick leave,

his last date of paid employment was October 18, 2012. In a letter dated

October 25, 2012, the Grant County Board of Education terminated Ashcraft

because no accommodations were available for light duty work in his job classification as an HVAC technician. His employer stated that even though

Ashcraft was given modified duties for five months, the job description for an

HVAC technician required the ability to lift up to 70 pounds.

Ashcraft requested an administrative hearing, which was held on

October 1, 2013. The hearing officer determined that Ashcraft submitted

sufficient objective medical evidence to support his assertion that the

cumulative effect of his neck, upper back, and lower back pain, and pain in his

left hip and leg physically incapacitated him on a permanent basis. In the

report dated December 18, 2013, the hearing officer recommended granting

Ashcraft’s disability benefits application, with review in two years. KERS filed

exceptions to the hearing officer’s recommendation.

The Disability Appeals Committee (DAC) of the Board of Trustees of the

Kentucky Retirement Systems (Board) met on February 21, 2014, and on

March 27, 2014,5 to consider the hearing officer’s recommendation. After fully

considering the administrative record, the DAC denied Ashcraft’s application

for disability benefits. In its findings, the DAC noted that two physicians

(Vaughn, Lyon), a vocational consultant (Crystal) and an exercise physiologist

(Pounds) determined that Ashcraft could lift up to 50 pounds, which is the

5 The online Minutes of the Disability Appeals Committee for February 21, 2014, reflect that the Ashcraft case was raised at that meeting. The members unanimously voted to reject the Hearing Officer’s Report and to issue an order denying the application. The order was not issued until the following month, when the Appeals Committee met on March 27, 2014. Minutes of Disability Appeals Committee - February 21, 2014, Kentucky Retirement Systems, https://kyret.ky.gov/About/ Board-of-Trustees/Committee%20Minutes/February212014DACMinutes.pdf. stated requirement for “medium duty work” as outlined in KRS 61.600(5)(c).

The DAC found that Ashcraft did not prove by a preponderance of objective

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