Pham v. Smithfield Foods

2025 S.D. 41
CourtSouth Dakota Supreme Court
DecidedJuly 23, 2025
Docket30859
StatusPublished

This text of 2025 S.D. 41 (Pham v. Smithfield Foods) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pham v. Smithfield Foods, 2025 S.D. 41 (S.D. 2025).

Opinion

#30859-r-MES 2025 S.D. 41

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

JODY PHAM, Claimant and Appellee,

v.

SMITHFIELD FOODS, SIOUX FALLS, Employer, Self-Insurer, and Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT MINNEHAHA COUNTY, SOUTH DAKOTA

THE HONORABLE DOUGLAS E. HOFFMAN Judge

LAURA K. HENSLEY KRISTIN N. DERENGE of Boyce Law Firm, LLP Sioux Falls, South Dakota Attorneys for employer, self- insurer, and appellant.

DAVID J. KING BRENDAN F. PONS of King Law Firm, P.C. Sioux Falls, South Dakota Attorneys for claimant and appellee.

ARGUED APRIL 30, 2025 OPINION FILED 07/23/25 #30859

SALTER, Justice

[¶1.] Jody Pham injured her neck and right shoulder while working at

Smithfield Foods, a self-insured employer. Smithfield accepted the injury as a

compensable workers’ compensation claim and, without a hearing or settlement

agreement, continued to pay workers’ compensation benefits for over two years.

However, in 2018, Smithfield stopped paying medical benefits because it believed

Pham’s employment was no longer a major contributing cause of her need for

additional treatment. Pham filed a petition for hearing with the Department of

Labor and Regulation (the Department), and an administrative law judge (ALJ)

determined that Pham failed to meet her burden to establish causation. Pham

appealed to the circuit court which reversed the ALJ’s decision, reasoning that by

initially accepting Pham’s claims as a compensable injury, the burden shifted to

Smithfield to show a change in circumstances to justify suspending benefits.

Smithfield appeals. We reverse the circuit court and reinstate the ALJ’s decision.

Factual and Procedural Background

[¶2.] Jody Pham was born and attended school in Vietnam. She immigrated

to the United States in 1994 and spent three months in Houston before moving to

Sioux Falls. She began working at Smithfield, which was then John Morrell’s, in

1996. She briefly left seeking warmer weather in Florida but returned to Sioux

Falls after a little over a year. She was rehired at Smithfield in 2008 and has

worked in the bacon department since then.

[¶3.] Pham reported neck and right shoulder issues to her manager in

August 2015. Her manager completed an employer’s first report of injury, and

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Smithfield internally placed her on a medical management plan, consisting of

heating and massages. After experiencing no improvement, Pham asked to see a

doctor, so Smithfield scheduled an appointment with Dr. Bruce Alden Elkins at

Avera Medical Group (AMG) Occupational Medicine and voluntarily began making

medical payments in accordance with South Dakota’s workers’ compensation

system.

[¶4.] On October 14, 2015, Pham first visited Dr. Elkins, who noted the

repetitive nature of Pham’s physically demanding job and diagnosed her with

sprained ligaments of her cervical spine and a strained right shoulder. Dr. Elkins

recommended conservative treatment and determined that Pham could return to

work with no restrictions. In subsequent visits to AMG Occupational Medicine,

Pham reported her right shoulder and neck pain were improving but noted

persistent headaches with increasing severity. For her headaches, she was advised

to follow up with her primary care physician.

[¶5.] Smithfield continued to pay for Pham’s medical treatment until mid-

2018. Perhaps most notable in this timeframe was Pham’s first surgery—a cervical

discectomy and fusion performed by Dr. Wissam Asfahani on April 19, 2017. The

surgery followed Pham’s complaints of numbness in her fingers and tingling in her

arms, as well as a subsequent December 2016 MRI, which revealed herniated C5-6

discs that were compressing Pham’s C6 nerve root. Though Dr. Asfahani did not

directly answer Smithfield’s request to offer an opinion as to whether Pham’s

employment was a major contributing cause of the need for surgery, Smithfield

ultimately paid for the surgery and related workers’ compensation benefits.

-2- #30859

[¶6.] Following surgery, Pham was placed on no-work status for three

months. She began physical therapy with Dawn Williams in June 2017 and

returned to work with temporary restrictions on July 24. Further, Dr. Asfahani

referred Pham to Dr. Travis Liddell at CORE Orthopedics, who ordered “a baseline

upper extremity EMG” during his initial evaluation. Dr. Todd Zimprich with AMG

Neurology conducted the EMG on August 31 and noted the results were “normal”

with “no convincing electrophysiologic evidence of radiculopathy . . . affecting the

right upper extremity.” Soon after, Williams informed Dr. Asfahani that she was

discharging Pham from physical therapy because Pham had reached maximum

improvement. In turn, Dr. Asfahani released Pham with no restrictions from a

neurological standpoint on September 21, 2017.

[¶7.] But Pham still had temporary restrictions from an orthopedic

standpoint. Dr. Liddell diagnosed Pham with adhesive capsulitis and recommended

physical therapy for her shoulder. Pham began another round of physical therapy

with Williams in January 2018. After a month, however, Williams informed

Smithfield’s Health Services Manager that Pham would be discharged from

physical therapy, noting that “[h]er pain remains relatively the same with or

without intervention.” She recommended a reevaluation from neurology and again

stated “maximal level reached” as the reason for Pham’s discharge from physical

therapy. Pham last visited Dr. Liddell at CORE on April 5, 2018, and he also

recommended that Pham follow up with Dr. Asfahani for a reevaluation at AMG

Neurology.

-3- #30859

[¶8.] It was around this time that Smithfield suspended workers’

compensation benefits. Following Dr. Liddell’s recommendation, a claims agent

messaged Dr. Asfahani inquiring as to whether he “need[ed] to see Ms. Pham to

determine if she [was] still at [maximum medical improvement] for the [October

2015 cervical injury].” No response from Dr. Asfahani appears in the record.

Further, in August 2018, Smithfield’s Health Services Manager requested an

independent medical examination (IME) from Dr. Ryan Noonan at AMG

Occupational Medicine. Specifically, Smithfield requested Dr. Noonan’s “opinion on

Permanent Partial Impairment for the cervical condition and surgery[.]” In his

August 30, 2018 IME report, Dr. Noonan concluded that Pham sustained an 8%

permanent partial whole person impairment (PPD) as a result of the October 2015

work injury.

[¶9.] Following the IME, Smithfield completed a memorandum of payment

for PPD which Pham refused to sign. The PPD memorandum was received by the

Department in November 2018 and reflected weekly PPD payments based on the

8% impairment rating totaling $14,804.62 in “[c]ompensation to be paid to the

employee for permanent physical impairment pursuant to SDCL 62-4-6[.]”

Smithfield sent a check to Pham for that amount on March 4, 2019, and the

Department notified Pham that Smithfield “can begin making payments of partial

disability benefits[.]”

[¶10.] Pham continued to seek and receive medical treatment under her

Smithfield-sponsored group health insurance throughout 2019 and 2020. Most

-4- #30859

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Bluebook (online)
2025 S.D. 41, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pham-v-smithfield-foods-sd-2025.