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Espindola v. Peter Pan Seafoods, Inc.         

ADMINISTRATIVE LAW

Sasha Kahn

In Espindola v. Peter Pan Seafoods, Inc., 486 P.3d 1116 (Alaska 2021), the supreme court held that while the Alaska Workers’ Compensation Board has authority to weigh the evidence provided by medical opinions, if the Board’s crucial findings are not supported by the record, under the substantial evidence standard, it has committed error. (Id. at 1121–23). A seasonal fish-processing worker filed for workers’ compensation for serious shoulder and lower-back pain resulting in his inability to consistently lift his arms above his head. (Id. at 1117–19). The doctor completing his Employer Medical Examination (EME) concluded that none of the issues arose from his work, and the company then controverted all claims. (Id. at 1118–19). A Second Independent Medical Evaluation (SIME) of the worker found that while the back issues persisted from before his work at the company, his shoulder problems likely arose out of a specific incident at work. (Id. at 1119). At the Board hearing, the doctor that completed the EME was the only one present, and the Board relied on his testimony to find in favor of the employer, briefly noting that the SIME was primarily based on the worker’s own account. (Id. at 1120). On appeal, the Alaska Workers’ Compensation Appeals Commission held that it was within the Board’s discretion to favor one doctor’s opinions over another’s. Reviewing the Commission’s holding de novo, the supreme court held that the evaluation of the back injury was sufficient because the Commission had adequately made findings about all contested and material issues. (Id. at 1122). However, the record did not support several of the Commission’s findings, including the contention that the SIME primarily utilized the worker’s own account regarding the injured shoulder. (Id. at 1122–23). The Commission’s holding with regards to the shoulder injury was therefore erroneous. (Id.). Affirming in part and reversing in part the Commission’s evaluation, the supreme court held that while the Alaska Workers’ Compensation Board has authority to weigh the evidence provided by medical opinions, if the Board’s crucial findings are not supported by the record, under the substantial evidence standard, it has committed error. (Id.).

Espindola v. Peter Pan Seafoods, Inc.         

ADMINISTRATIVE LAW

Sasha Kahn

In Espindola v. Peter Pan Seafoods, Inc., 486 P.3d 1116 (Alaska 2021), the supreme court held that while the Alaska Workers’ Compensation Board has authority to weigh the evidence provided by medical opinions, if the Board’s crucial findings are not supported by the record, under the substantial evidence standard, it has committed error. (Id. at 1121–23). A seasonal fish-processing worker filed for workers’ compensation for serious shoulder and lower-back pain resulting in his inability to consistently lift his arms above his head. (Id. at 1117–19). The doctor completing his Employer Medical Examination (EME) concluded that none of the issues arose from his work, and the company then controverted all claims. (Id. at 1118–19). A Second Independent Medical Evaluation (SIME) of the worker found that while the back issues persisted from before his work at the company, his shoulder problems likely arose out of a specific incident at work. (Id. at 1119). At the Board hearing, the doctor that completed the EME was the only one present, and the Board relied on his testimony to find in favor of the employer, briefly noting that the SIME was primarily based on the worker’s own account. (Id. at 1120). On appeal, the Alaska Workers’ Compensation Appeals Commission held that it was within the Board’s discretion to favor one doctor’s opinions over another’s. Reviewing the Commission’s holding de novo, the supreme court held that the evaluation of the back injury was sufficient because the Commission had adequately made findings about all contested and material issues. (Id. at 1122). However, the record did not support several of the Commission’s findings, including the contention that the SIME primarily utilized the worker’s own account regarding the injured shoulder. (Id. at 1122–23). The Commission’s holding with regards to the shoulder injury was therefore erroneous. (Id.). Affirming in part and reversing in part the Commission’s evaluation, the supreme court held that while the Alaska Workers’ Compensation Board has authority to weigh the evidence provided by medical opinions, if the Board’s crucial findings are not supported by the record, under the substantial evidence standard, it has committed error. (Id.).