Whitener v. South Central Solid Waste Authority

1989 OK 62, 773 P.2d 1248, 1989 Okla. LEXIS 67, 1989 WL 36111
CourtSupreme Court of Oklahoma
DecidedApril 18, 1989
Docket69224
StatusPublished
Cited by37 cases

This text of 1989 OK 62 (Whitener v. South Central Solid Waste Authority) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Whitener v. South Central Solid Waste Authority, 1989 OK 62, 773 P.2d 1248, 1989 Okla. LEXIS 67, 1989 WL 36111 (Okla. 1989).

Opinion

OPALA, Vice Chief Justice.

The dispositive issue on certiorari is whether the employer’s medical letter-report, on which the trial tribunal’s decision is rested, lacks probative value and hence cannot support the denial of permanent disability benefits to the claimant. We answer in the negative.

I.

ANATOMY OF LITIGATION

Claimant, Corbin H. Whitener, sought compensation benefits for job-related harm he sustained while employed by South Central Solid Waste Authority, whose risk carrier is State Insurance Fund [collectively called employer]. According to the transcript, the claimant’s medical report was admitted without objection. His physician rated compensable disability at 35% permanent partial respiratory impairment. When the employer tendered its physician’s report, which found the claimant to be free of permanent impairment, the claimant “objected” to the exhibit’s admission solely for lack of probative value. 1 The trial judge admitted the report and “noted” the challenge to its probative effect but made no ruling on this issue. 2

The trial tribunal found the claimant’s continuous inhalation of “harmful dust, smoke and fumes” caused him to suffer “an occupational disease consisting of injury to the lungs and upper respiratory system” but concluded that he had sustained no permanent partial disability. The claimant sought review.

In the Court of Appeals the claimant argued the employer’s medical evidence does not support the benefits’ denial because 1) it is “incompetent” and 2) it lacks probative value since the physician failed to evaluate the claimant’s compensable harm in accordance with the American Medical Association’s “Guides to the Evaluation of Permanent Impairment” [the Guides]. 3 Their use is required by the terms of 85 O.S.Supp.1987 § 3(H). 4 For reasons not *1250 explained in any detail, the appellate court concluded that the employer’s medical report "... was not in substantial compliance with 85 O.S.1981, ch. 4, app., Rule 20, and was not competent evidence.” The claim was remanded with instructions to award the claimant benefits for “35% permanent partial impairment to the body as a whole” —the rating given in his physician’s report. We now grant certiorari upon employer’s petition.

The only issue to be addressed is whether the employer’s medical report has probative value. Its admissibility or “competence" is not before us. This is so because the claimant waived his objection to the report when he did not contest that exhibit’s admissibility at the time of its offer into evidence. 5 Upon claimant’s failure to object timely, the report stood admitted by force of Rule 21, Rules of the Workers’ Compensation Court. 6

II.

THE EMPLOYER’S MEDICAL REPORT DOES NOT LACK PROBATIVE VALUE FOR FAILURE TO COMPLY WITH THE AMA GUIDES

Claimant urged the “pulmonary function studies” described in the employer’s medical report deviate from the Guides’ requirements and sap the report of probative effect insofar as the claimant’s lungs were found to be free from permanent impairment. In our view, the employer’s medical report conforms to the standards prescribed by the Guides, and the values attributed to the claimant’s condition are consistent with the report’s ascribed rating of no permanent impairment. The trial tribunal’s denial of benefits for respiratory impairment hence rests on medical evidence which is probative of the compensable harm’s rating.

*1251 The claimant initially attacks the employer’s report, arguing that the results of two of the three measurements or tests, which were either made by the physician or capable of being made by calculation, warrant a finding that the claimant is 10-25% impaired. 7 The Guides clearly state: “if an impairment is to be rated,” then “at least one of these [three] measures of ven-tilatory function should be abnormal to the degree described in a given class definition.” 8 [Emphasis added.] While the claimant maintains that this rule somehow works to his advantage, he admits “[t]here is nothing in ... [the] report that casts any doubt on the validity of the pulmonary function study results he [the employer’s medical expert] relies on.” Even if we were to assume, as the claimant urges, that the data from two of the three tests do indicate permanent impairment, the third test’s result supports the physician’s conclusion that the claimant sustained no permanent impairment. 9 Inasmuch as an impairment rating may be rested on the results of but one of the three breathing measurements, we conclude that the employer’s medical report is not fatally deficient in probative force. The Guides clearly permit alternative conclusions when evaluating the same raw data. 10

The claimant next contends that the employer’s medical expert’s opinion is defective because, without an explanation by the physician in his report, some of its numerical data deviate from those which should have been used according to the Guides. The claimant seems to argue that regardless of whether the numbers have any impact on impairment classification, the report has no probative value because it contains inaccurate or erroneous data. In our view, the physician’s data analysis substantially conforms to the AMA Guides’ standards.

A medical expert’s permanent impairment evaluation must substantially comply with the methods and standards prescribed by the Guides. 11 Noncompliance may be apparent from mere reference to the Guides. That was the case in LaBarge v. Zebco. 12 There, a specific impairment percentage for each of two ruptured discs that required surgery was plainly mandated by the AMA manual and ignored by the rating physician. The LaBarge test for determining whether the standards are followed when clearly applicable is whether, from a medical report’s four corners, an unexplained, facially apparent and substantial deviation from the Guides can be detected by mere reference to their text. The claimant’s attack on the employer’s letter-report calls for a different analysis of its probative force.

Here, the Guides contain tables from which “normal” values are obtained according to raw data, i.e., height and age. A constant, called the “95% Confidence Interval,” must

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Bluebook (online)
1989 OK 62, 773 P.2d 1248, 1989 Okla. LEXIS 67, 1989 WL 36111, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whitener-v-south-central-solid-waste-authority-okla-1989.