## Facts

- Daniel Decker worked as a sheet-metal worker, including fabrication, assembly, and installation of ductwork, and began working for Mountain Aire in October 2000.
- His job involved frequent overhead work and repetitive upper-extremity activity.
- In August 2001, Decker felt one wrist “pop” while pulling sheet metal from under a bench; shortly afterward, he felt his other wrist “pop” while cutting tin, and his wrists became sore.
- Decker sought medical care and was evaluated over time by numerous healthcare providers; by the time of the contested-case hearing, he had been examined by nine physicians and one psychologist, including two independent medical examiners.
- Decker claimed workers’ compensation benefits on the theory that his work activities materially aggravated symptoms associated with thoracic outlet syndrome (TOS).
- The Wyoming Workers’ Safety and Compensation Division denied the claim, and the dispute was referred to the Wyoming Medical Commission for a contested-case hearing before a medical panel.
- At the hearing, Decker presented evidence from treating physicians supporting a link between his work (including overhead duties) and his condition; the Division relied heavily on independent medical examinations that disputed work-related causation.
- The Medical Commission credited the independent medical examiners, found Decker not credible, discounted the treating physicians’ opinions as reliant on an inaccurate history attributed to Decker, and upheld the denial of benefits.
- Decker appealed and argued, among other things, that his due-process rights were violated because the medical panel did not deliberate in a public meeting and did not allow him to present additional evidence.
- The case returned to the Wyoming Supreme Court after further proceedings, with the Medical Commission again denying benefits and Decker renewing both merits and due-process challenges.

## Issues

1. Whether substantial evidence supported the Medical Commission’s determination that Decker failed to prove his work materially aggravated his thoracic outlet syndrome.
2. Whether the Medical Commission acted arbitrarily or capriciously in rejecting treating-physician opinions and relying primarily on independent medical examinations and a negative credibility finding.
3. Whether Decker was denied due process when the Medical Commission deliberated without him present and, after remand, did not allow additional evidence or argument before issuing a supplemental decision.

## Decision

- The Wyoming Supreme Court reversed the Medical Commission’s denial of benefits, concluding the decision was not supported by substantial evidence when the record was considered as a whole.
- The Court determined the Medical Commission’s handling of the evidence—especially its broad rejection of treating-physician causation opinions based largely on a credibility finding—did not have adequate support in the record.
- The Court held that the Medical Commission’s procedures did not violate due process under the circumstances: Decker was not entitled to attend the panel’s deliberations, and the Commission could issue a supplemental order on the existing record without taking new evidence.
- Disposition: reversed the denial of benefits (while rejecting the due-process challenge to the Commission’s deliberation and remand procedure).

## Legal Principles

- A workers’ compensation claimant bears the burden to prove compensability, including medical causation, by a preponderance of the evidence.
- Compensation may be awarded when work activities materially aggravate, accelerate, or combine with a preexisting condition to produce disability or the need for treatment.
- On judicial review of agency action, courts apply Wyoming APA standards, including substantial-evidence review of factual findings and review for arbitrary or capricious agency action.
- “Substantial evidence” means relevant evidence that a reasonable mind might accept as adequate to support the agency’s conclusion; the reviewing court evaluates the entire record rather than isolating evidence supporting the agency result.
- An agency may choose between conflicting medical opinions, but it must explain its reasoning and may not disregard significant medical evidence without a record-based explanation.
- Credibility determinations are generally for the agency as fact-finder, but a credibility finding must still be supported by the record and cannot be used as a blanket substitute for evaluating medical evidence.
- Due process in an administrative contested case requires notice and a meaningful opportunity to be heard at the hearing; it does not necessarily include a right to attend agency deliberations or participate in drafting the written decision.
- After a remand directing improved findings, an agency may issue a supplemental order based on the existing record when the remand does not require reopening the evidence.

## Conclusion

Claim of Decker v. Wyoming Medical Commission holds that the Medical Commission’s denial of benefits for an alleged work-related aggravation of thoracic outlet syndrome lacked substantial evidentiary support and therefore could not stand, even though the Commission’s private deliberations and issuance of a supplemental decision without reopening the record did not, on these facts, deny due process.


Claim of Decker v. Wyoming Medical Commission, 191 P.3d 105 (2008)