## Facts

- Roberta Adams worked for about a year as a telemarketer, manually dialing numbers and holding a telephone receiver without a headset.
- Adams developed increasing physical complaints, including neck pain and stiffness, muscle spasms, right arm and shoulder pain, numbness or “pins and needles,” and fatigue, and she stopped working to seek treatment.
- A chiropractor diagnosed several conditions (including carpal tunnel syndrome) described as a repetitive-motion syndrome and opined they were likely caused by Adams’s job duties.
- Other providers agreed with aspects of the repetitive-motion diagnosis and linked Adams’s symptoms to her work, while some physicians identified alternative explanations, including degenerative cervical disc disease.
- The Workers’ Compensation Fund required Adams to undergo independent medical evaluations; several Fund-retained doctors concluded Adams’s major problems were psychological rather than work-caused physical impairment.
- A psychologist examined Adams and concluded she did not have a physical impairment.
- At an evidentiary hearing, the parties presented conflicting medical and psychological opinions on diagnosis, causation, and impairment.
- The administrative law judge (ALJ) denied benefits, finding that Adams had not shown her employment caused her symptoms.
- Adams appealed within the agency; the Industrial Commission’s Board of Review affirmed by adopting the ALJ’s findings of fact and conclusions of law as its own.
- Adams sought judicial review in the Utah Court of Appeals.

## Issues

1. Whether substantial evidence supported the Board of Review’s (adopted) findings that Adams failed to prove her telemarketing work caused a compensable injury or occupational disease.
2. Whether the Board of Review acted within its authority in adopting the ALJ’s findings and conclusions and denying benefits despite conflicting medical opinions.

## Decision

- The Utah Court of Appeals affirmed the Board of Review’s decision denying benefits.
- The court held that resolving conflicts in expert medical testimony was for the Industrial Commission, not the reviewing court.
- Because evidence in the record supported the agency’s causation and impairment findings, the denial of benefits was upheld under the substantial-evidence standard.

## Legal Principles

- In judicial review of an administrative workers’ compensation decision, the reviewing court does not reweigh evidence; it asks whether the agency’s findings are supported by substantial evidence in the record.
- When qualified experts present conflicting medical opinions, the Industrial Commission may choose which evidence to credit, and its choice will be upheld if supported by substantial evidence.
- The claimant bears the burden to prove a causal connection between employment and the claimed injury or occupational disease.
- The Board of Review may adopt an ALJ’s findings and conclusions as its own; on review, those adopted findings are treated as the agency’s findings.

## Conclusion

The court affirmed the Industrial Commission’s denial of benefits because the agency, faced with conflicting medical and psychological evidence, found Adams did not carry her burden to prove work-related causation, and that determination was supported by substantial evidence.


Adams v. Board of Review of Industrial Commission, 821 P.2d 1 (1991)