Claimant sustained an injury to his left knee in 2007 when he fell off of a trash truck in the course and scope of his employment with Employer.  He underwent a left knee replacement, and Employer paid medical and indemnity benefits.  In 2014, Claimant presented to his treating physician with complaints of right knee pain.  The treating doctor provided a steroid injection and ordered an MRI scan.  Claimant presented for a second opinion, and that physician concluded that no diagnostic studies or further treatment were necessary.  Employer declined to pay for any treatment related to Claimant’s right knee.  Claimant filed a Disputed Claim for Compensation seeking medical benefits for his right knee.  The OWC ordered an independent medical examination, and the examiner opined that Claimant’s complaints were not related to his job injury.  The matter went to trial, and the workers’ compensation judge awarded Claimant benefits for his right knee.

Employer appealed the judgment, arguing that the trial court erred by concluding that the right knee injury was causally connected to the 2007 work accident.  Claimant argued that the decision should be affirmed because the trial court properly afforded greater weight to the opinion of the treating physician.  The appellate court disagreed with the trial court and with Claimant.  Upon further inspection, the treating doctor did not causally relate the right knee complaints to the work injury.  The report simply stated that the Claimant reported to the treating doctor that due to Claimant favoring his right knee as a result of injuries to his left knee, his right knee was bothering him.  The doctor did not actually provide an opinion to this regard, and was silent on the issue of causation.  Therefore, the only medical evidence in the record that addresses causation is that of the independent medical examiner, who opined that Claimant’s complaints were not related to his job injury.  The appellate court therefore held that the workers’ compensation court was manifestly erroneous in rendering a judgment in favor of Claimant.

LaSalle v. City of Lake Charles