Riley v. F.A. Richard & Associates, Inc.

16 So. 3d 708, 2009 Miss. App. LEXIS 81, 2009 WL 368342
CourtCourt of Appeals of Mississippi
DecidedFebruary 17, 2009
Docket2007-CA-00755-COA
StatusPublished
Cited by7 cases

This text of 16 So. 3d 708 (Riley v. F.A. Richard & Associates, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Riley v. F.A. Richard & Associates, Inc., 16 So. 3d 708, 2009 Miss. App. LEXIS 81, 2009 WL 368342 (Mich. Ct. App. 2009).

Opinion

BARNES, J.,

for the Court.

¶ 1. After a work-related maritime injury, Joe Riley sued Ingalls Shipbuilding Inc. (now Northrop Grumman Ship Systems, Inc.); its self-insured claims administrator, F.A. Richard & Associates, Inc. (FARA); and case manager Alexis Hyland (collectively, the Defendants or Appellees) for numerous claims of negligence and intentional tort. The essence of Riley’s complaint was that due to an ex parte meeting between Hyland and Riley’s treating physician, the physician was influenced to give a medical review favorable to the employer regarding Riley’s back injury. The Jackson County Circuit Court granted summary judgment in favor of the Defendants. Finding no error, we affirm the circuit court’s decision.

STATEMENT OF FACTS AND PROCEDURAL HISTORY

¶ 2. On October 16, 1997, in Pascagoula, Mississippi, Riley sustained a serious maritime industrial injury while working at In-galls Shipbuilding Inc. (Ingalls) when he accidentally fell from an I-beam several feet to the floor and shattered the bones above his left ankle. The following day, emergency surgery was performed on Riley’s lower leg and ankle. After the surgery, while in the hospital, Riley called *711 “workers comp” at Ingalls to let them know he was in the hospital and to initiate his claim. As a result, on October 21, 1997, while still in the hospital, Riley met with Caty Suthoff, a claims adjuster for FARA. Suthoff received Riley’s permission to tape the conversation, a transcription of which is included in the record before this Court. At the beginning of the interview, Suthoff explicitly stated that she was interviewing him concerning his industrial injury and that she worked for FARA, “representing Ingalls Shipbuilding.” A review of this transcript shows Riley to be quite lucid: he responded appropriately and in detail to questions, providing his badge number, social security number, and other pertinent information quite readily. At this interview, Riley signed a one-page document, which contained a “Medical Authorization,” “Claim Information Release,” and “Choice of Physician Form.” 1 The Medical Authorization stated:

I, the undersigned, [Riley], do hereby voluntarily, specifically, and unconditionally authorize any physician, nurse, hospital, or other medical provider, to furnish, discuss or confer with Ingalls Shipbuilding, Inc., its agents, attorneys, and/or representative, all records and information regarding my past or present physical or emotional condition and treatment rendered therefor. I further understand that all of my past or present treatment may be relevant and accordingly, consent to the release of all medical information.... Revocation of this document can only be made by myself and only through a written instrument, signed by me and a representative of Ingalls Shipbuilding, Inc. in whose favor this medical release is granted.

(Emphasis added.) The document was witnessed by Suthoff and signed by Riley in five different places, two of which were for the Medical Authorization. 2 It is undisputed that Ingalls voluntarily and properly commenced payment of all pertinent medical and workers’ compensation benefits regarding Riley’s ankle injury until the final adjudication of his Longshore and Harbor Workers’ Compensation Act (LHWCA) claim. 3

¶ 3. After his release from the hospital, on November 3,1997, Riley saw Dr. Christopher Wiggins who took over Riley’s orthopedic treatment. 4 On February 12, 1998, Dr. Wiggins found it necessary to perform a subsequent surgery on Riley’s left ankle, a fusion, which left his injured ankle one and one-half inches shorter than the other. Dr. Wiggins opined, after a functional capacity evaluation, that Riley’s date of maximum medical improvement was September 16, 1998, with an impairment rating of fifty percent for his foot.

¶ 4. In September 1998, Riley retained a law firm in connection with his workers’ compensation case, and shortly thereafter, *712 one of the firm’s lawyers sent Suthoff a letter asking her to “cease any contact” with Riley. The letter did not address or revoke the Medical Authorization which Riley had signed in October 1997. In March 1999, Riley’s counsel mistakenly filed an application for lump-sum payment with the Mississippi Workers’ Compensation Commission (Commission). Riley’s counsel received a letter from FARA in response, informing him that the Commission did not have jurisdiction over Riley’s claim. Instead, the claim was being handled under the LHWCA, with the U.S. Department of Labor having jurisdiction over the claim. 5

¶ 5. On March 9, 1999, Riley had an office visit with Dr. Wiggins about his custom shoe for his injured foot, when Dr. Wiggins noted for the first time that Riley also complained of back pain. Dr. Wiggins’s medical notes state that: “I was not aware of prior back problems before. [Riley] says he mentioned it to me several times, but apparently no note was made of it. He says all he knows is that his back has been hurting him since the fall and has steadily gotten worse to the point now that he can hardly put up with it.” Upon physical examination and X-rays, Dr. Wiggins noted that Riley had a “very severe limp” and diagnosed him with “spondylolysis L4 possibly aggravated by his industrial injury of 10/16/97 and a severe gait disturbance.” 6 Dr. Wiggins summarized that, “[fjrom a workers’ compensation standpoint, the more difficult problem is his back pain .... the man does have a severe gait disturbance and he did sustain a fall[,] both of which are reasonable to have caused the increasing pain from his preexisting, but previously asymptomatic, spon-dylolysis. The workers’ compensation carrier may wish to take this point under advisement.” FARA was provided a copy of these medical notes. These notes were FARA’s first knowledge of any allegation of a back injury related to Riley’s fall.

¶ 6. On April 19, 1999, Riley saw Dr. Wiggins for “reevaluation.” Dr. Wiggins’s medical notations indicate Riley still complained of back pain. Dr. Wiggins noted that Riley had not worked since the accident in October 1997, and in his estimation, Riley was “fully disabled.” Dr. Wiggins concluded that “[t]his man is disabled for all substantial gainful employment.” Near this comment, there was a handwritten notation that specified “from a social security standpoint.” Dr. Wiggins later explained that he had added this notation after his meeting 7 with Hyland, a registered nurse and medical case manager for FAR assigned to Riley’s workers’ compensation case, because it is key language for social security disability, which Riley was attempting to obtain at the time.

¶ 7. The basis of Riley’s instant lawsuit is Hyland’s June 7, 1999, meeting with Dr. Wiggins. The Appellees’ brief explains that Hyland was employed by FAR for claim consulting with physicians regarding such things as medical injury causation, diagnosis, prognosis, and treatment. Hy-land’s employment notes indicate that she was instructed by FAR to consult with Dr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Green Acres Trust v. Wells
72 So. 3d 1123 (Court of Appeals of Mississippi, 2011)
Lambert v. Baptist Memorial Hospital-North Mississippi, Inc.
67 So. 3d 799 (Court of Appeals of Mississippi, 2011)
Perkins v. Wal-Mart Stores, Inc.
46 So. 3d 839 (Court of Appeals of Mississippi, 2010)
Hodges v. Attala County
42 So. 3d 624 (Court of Appeals of Mississippi, 2010)
Evans v. Mississippi Department of Human Services
36 So. 3d 463 (Court of Appeals of Mississippi, 2010)
Moore v. M & M LOGGING, INC.
51 So. 3d 216 (Court of Appeals of Mississippi, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
16 So. 3d 708, 2009 Miss. App. LEXIS 81, 2009 WL 368342, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riley-v-fa-richard-associates-inc-missctapp-2009.