Lydon v. Sprinkler Services

2004 ME 16, 841 A.2d 793, 2004 Me. LEXIS 16
CourtSupreme Judicial Court of Maine
DecidedFebruary 12, 2004
StatusPublished
Cited by12 cases

This text of 2004 ME 16 (Lydon v. Sprinkler Services) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lydon v. Sprinkler Services, 2004 ME 16, 841 A.2d 793, 2004 Me. LEXIS 16 (Me. 2004).

Opinions

Majority: SAUFLEY, C.J., and RUDMAN, DANA, ALEXANDER, and CALKINS, JJ.

Dissent: CLIFFORD and LEVY, JJ.

SAUFLEY, C.J.

[¶ 1] We are called upon to determine whether a physician may be appointed to serve as an independent medical examiner in a workers’ compensation proceeding, pursuant to 39-A M.R.S.A. § 312 (2001), if that physician has performed examinations of other employees at the request of an employer, insurer, or employee, pursuant to 39-A M.R.S.A. § 207 (2001 & Supp. 2003). In the matter before us, a hearing officer of the Workers’ Compensation Board (.McCurry, HO), denied Joseph Ly-don’s petition for award and did so in reliance on the opinion of an independent medical examiner who had conducted examinations of other employees pursuant to 39-A M.R.S.A. § 207 within fifty-two weeks prior to examining Lydon. See 39-A M.R.S.A. § 312(2). We conclude that the physician was ineligible to serve as an independent medical examiner and vacate the decision.

I. BACKGROUND

[¶ 2] In August 2001, Lydon filed petitions for award and to fix medical payment for an alleged work-related back injury on April 7, 1999, during his employment with Sprinkler Services. Lydon did not need medical care immediately after the alleged injury, but experienced problems in early May and underwent back surgery on May 27,1999, to remove a synovial cyst.

[¶ 3] The parties’ experts disagreed as to whether the cyst or the aggravation of Lydon’s back injury were work related. As a result of this dispute, Sprinkler Services sought the appointment of an independent medical examiner (IME) pursuant to 39-A M.R.S.A. § 312. When the parties could not agree on an IME, the hearing officer appointed an IME to examine Lydon. See 39-A M.R.S.A. § 312(3) (2001).

[If 4] Lydon objected to the physician appointed as the IME, alleging that the doctor had performed a number of section 207 examinations on behalf of employers in [795]*795the preceding fifty-two weeks and was therefore not sufficiently independent. In response to this objection, the hearing officer granted Lydon’s request to serve the IME with interrogatories requesting information concerning the number of section 207 examinations the doctor performed in the preceding fifty-two weeks, “who he did them for and the amount of money that he was paid.”

[¶ 5] The IME declined to respond to the interrogatories, was not forthcoming during his subsequent deposition, and refused to answer most of the questions concerning the sources of his professional income that were related to workers’ compensation. He did, however, give limited answers at the hearing, estimating that 20% of his practice is devoted to performing medical examinations for legal purposes, which included both section 207 examinations and section 312 examinations, and which accounted for approximately 10% of his income (with no indication of the amount of his income). He declined to give an approximation of the proportion of the examinations devoted to section 207 examinations as opposed to section 312 examinations. He declined to give even minimal information concerning how much money he earned in the preceding year for performing section 207 examinations at an employer’s request.1

[¶ 6] Notwithstanding the doctor’s testimony that he had performed numerous section 207 examinations within the past year, and notwithstanding his refusal to provide information necessary to a separate assessment of his possible conflicts of interest, the hearing officer ultimately relied on the IME’s opinion in denying Ly-don’s petition.2 In so doing, the hearing officer concluded in essence that neither the workers’ compensation statutes nor the Workers’ Compensation Board Rules automatically preclude a doctor who has performed any section 207 examinations within the preceding year from acting as an IME.

[¶ 7] The hearing officer denied Lydon’s motion for findings of fact and conclusions of law, and we granted his petition for appellate review.

II. DISCUSSION

[¶ 8] Independent Medical Examiners are governed by 39-A M.R.S.A. § 312. IMEs must be “the most qualified and ... highly experienced and competent in their specific fields of expertise.” Id. § 312(1). When opposing parties agree on the selection of the IME, the IME’s opinion is binding. Id. § 312(7). When the parties cannot agree, the Board may appoint an IME and is then required to adopt the IME’s findings in the absence of clear and convincing evidence to the contrary. Id. § 312(3), (7).

[¶ 9] A primary purpose of the IME system is to prevent “doctor shopping” and to reduce litigation. As one legislator remarked:

[T]he new law clearly does establish the IME and does establish the criteria for the IME so that it may not be rebutted other than by clear and convincing evidence. That is a higher standard, it does away with doctor shopping, there would be much more doctor shopping [796]*796under the old law, there would be much more running to different experts and having a contentious type of situation where the insurers hire experts and the employee hires experts. The whole process is attempting to change this method of doing business.

7 Legis. Rec. H-61 (3rd Spec.Sess.1992) (Statement of Rep. Hastings). We have noted the importance of the integrity of the IMEs in other opinions. “Because of the significance of the IME’s role, independence, integrity, and absence of conflict of interest are important.” Laskey v. S.D. Warren Co., 2001 ME 103, ¶ 18, 774 A.2d 358, 363.3

[¶ 10] In order to assure the independence of independent medical examiners, the Legislature has restricted those who may serve in that capacity. See 39-A M.R.S.A. § 312(2) (2001).4 There are three primary restrictions. First, the employee’s “treating health care provider” may not act as an IME in that employee’s case. Id. Second, the doctor “may not have treated the employee with respect to the injury for which the claim is being made.” Id. And third, “[a] physician who has examined an employee ... in accordance with section 207 during the previous 52 weeks” may not serve as an IME. Id.

[¶ 11] The question before us is whether the third restriction applies only to a section 207 examination of the employee whose case is at issue or applies to a section 207 examination of any employee. The analysis centers on the word “an” in the last sentence of section 312(2), specifically: “A physician who has examined an employee at the request of an insurance company, employer or employee in accordance with section 207 during the previous 52 weeks is not eligible to serve as an independent medical examiner.” Id. § 312(2) (emphasis added). Lydon argues that “an employee” means “any ” employee, but Sprinkler urges us to conclude that the term “an employee,” in this context, must be read to refer to the specific employee whose case is at issue. If, as Ly-don argues, a physician is ineligible for appointment as an IME if he or she has performed any section 207 examinations within the preceding year, then the physician in the matter before us was not eligi[797]*797ble and the hearing officer’s reliance on his opinion was in error.

[¶ 12] We must begin our analysis by addressing the plain language of the statute.

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Cite This Page — Counsel Stack

Bluebook (online)
2004 ME 16, 841 A.2d 793, 2004 Me. LEXIS 16, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lydon-v-sprinkler-services-me-2004.