Packers Sanitation Services v. Jorge Martell Cabrera

CourtKentucky Supreme Court
DecidedMarch 22, 2021
Docket2020 SC 0215
StatusUnknown

This text of Packers Sanitation Services v. Jorge Martell Cabrera (Packers Sanitation Services v. Jorge Martell Cabrera) 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
Packers Sanitation Services v. Jorge Martell Cabrera, (Ky. 2021).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4)(C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: MARCH 25, 2021 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2020-SC-0215-WC

PACKERS SANITATION SERVICES APPELLANT

ON APPEAL FROM THE COURT OF APPEALS V. NO. 2019-CA-1846 WORKERS’ COMPENSATION BOARD NO. WC-14-66805

JORGE MARTELL CABRERA; APPELLEES HONORABLE JOHN BARRY COLEMAN, ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD

MEMORANDUM OPINION OF THE COURT

AFFIRMING

Packers Sanitation Services appeals from the Court of Appeals’ opinion

affirming the Workers’ Compensation Board’s opinion affirming the

Administrative Law Judge’s (ALJ) award of permanent-partial disability benefits

to Jorge Martell Cabrera. Asserting this case differs from “the run-of-the mill”

substantial-evidence case, Packers Sanitation argues the Court of Appeals

erred in affirming the ALJ’s award because, despite other evidence of record,

surveillance-video footage of Cabrera submitted by Packers Sanitation proves

Cabrera hoodwinked the medical experts by faking his symptoms, resulting in

an arbitrary award. We find no error, and we affirm the Court of Appeals. I. FACTS

Cabrera worked for Packers Sanitation providing cleaning services at the

JB Swift meat processing plant in Louisville, Kentucky. In the course and

scope of his employment, Cabrera slipped as he was cleaning a metal conveyor

belt and both arms became caught in the works of the conveyor, resulting in

severe cuts to both arms. Treatment required emergency debridement and

surgery. Infection necessitated repeated later surgical procedures and removal

of muscle tissue. Cabrera eventually returned to work in a different capacity

and eventually was promoted to a supervisory position at a higher rate of pay.

He sought workers’ compensation benefits for both physical and psychological

injuries for which the ALJ awarded benefits.

Packers Sanitation appealed to the Board, arguing the ALJ’s findings

supporting the benefits were a sham, asserting, as it later did to the Court of

Appeals and now to us on appeal, that surveillance video clips it introduced

into the record conclusively refute Cabrera’s claims of functional impairment

by showing him going about activities of daily living using his hands and arms

without apparent difficulty. Packers Sanitation contends that if the Board had

simply watched the video clips, then it would have reached the inescapable

conclusion that the medical and psychological evidence relied upon by the ALJ

was bogus, rendering the ALJ’s award of benefits arbitrary and requiring

reversal.

2 II. ANALYSIS

A. The Board and Court of Appeals did not err in failing to reverse the ALJ’s factual findings because they were supported by substantial evidence and affirmance was not an abuse of discretion.

At the hearing before the ALJ, Packers Sanitation introduced a series of

video clips of Cabrera prepared by a private investigator hired in connection

with separate civil litigation between Cabrera and Swift. The video shows

Cabrera engaging in activities using his hands and arms. Packers Sanitation

avers the video evidence alone is conclusive proof that Cabrera exaggerated his

injuries and retains minimal functional impairment despite the conflicting

evidence from Cabrera and the medical reports of record. Because Packers

Sanitation finds the video to be conclusive, it argues that the Board could not

have reviewed the surveillance video, because if it had, the Board would have

been constrained to conclude that Cabrera was a fraud and the ALJ’s finding of

impairment arbitrary.

Appellate review in workers’ compensation proceedings is limited to

correcting the Board where it has misconstrued statutes or precedent or

committed error in assessing evidence so flagrant as to cause gross injustice.1

We will not reverse the ALJ’s decision solely because there is evidence in the

record that appears contrary to the factual findings of the ALJ.2 Of course, the

ALJ’s factual findings must be supported by substantial evidence, which

1 W. Baptist Hosp. v. Kelly, 827 S.W.2d 685, 687–88 (Ky. 1992). 2 Whittaker v. Rowland, 998 S.W.2d 479, 482 (Ky. 1999).

3 requires evidence of substance and consequence and trustworthy enough to

induce conviction in reasonable minds.3

We find, as the Court of Appeals found, that substantial evidence in this

record supports the Board’s decision to uphold the ALJ’s findings. Packers

Sanitation dismisses as preposterous the Board’s acceptance of the ALJ’s

findings of fact considering the video. The influence the videos have on the

trier of fact is a question of interpretation. As the ALJ explained, the video may

show Cabrera capable of physical activity beyond what he described in the

record, but the objective evidence of his condition, as reflected in the medical

records, indicates he is impaired and that he did not believe Cabrera to be

“malingering or faking.” Overall, the ALJ’s findings discuss the video

considering all the evidence presented, and his findings conclude that the video

did not overcome the proof of Cabrera’s impairment.

The weight given to the video is a question of fact, and it is not conclusive

as to Cabrera’s impairments, especially considering the conflicting evidence

presented by Cabrera. The ALJ concluded that the objective medical evidence

was more persuasive. And we find the order sufficiently described why the ALJ

found the video to be inconclusive and why he ultimately found Cabrera to be

impaired. We hold it was not error for the Board to affirm the order awarding

Cabrera partial-permanent disability benefits.

3 Smyzer v. B.F. Goodrich Chem. Co., 474 S.W.2d 367, 369 (Ky. 1971).

4 B. The ALJ did not err as a matter of law by relying on Dr. Ruth’s initial report.

In 2016, Cabrera underwent a psychological impairment assessment by

Dr. Douglas Ruth, who found he suffered from major depressive disorder and

post-traumatic stress disorder with an overall psychological impairment of 8%

because of his work-related injury. Later, after seeing the video footage of

Cabrera, Dr. Ruth concluded Cabrera was likely malingering. Dr. Ruth then

gave Cabrera a second assessment that was like the first and contained several

self-report measures. While Cabrera performed similarly on the self-report

measures, Dr. Ruth found the video footage indicated he was capable of more

than his self-report measures revealed. Ultimately, Dr. Ruth changed his

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Related

Cepero v. Fabricated Metals Corp.
132 S.W.3d 839 (Kentucky Supreme Court, 2004)
Whittaker v. Rowland
998 S.W.2d 479 (Kentucky Supreme Court, 1999)
Smyzer v. BF Goodrich Chemical Company
474 S.W.2d 367 (Court of Appeals of Kentucky (pre-1976), 1971)
Western Baptist Hospital v. Kelly
827 S.W.2d 685 (Kentucky Supreme Court, 1992)
Abel Verdon Construction v. Rivera
348 S.W.3d 749 (Kentucky Supreme Court, 2011)

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Packers Sanitation Services v. Jorge Martell Cabrera, Counsel Stack Legal Research, https://law.counselstack.com/opinion/packers-sanitation-services-v-jorge-martell-cabrera-ky-2021.