## Facts

- Robert Lettich sought workers’ compensation, alleging that work-related stress aggravated a preexisting coronary artery disease.
- After a conference before a single member of the Industrial Accident Board, benefits were denied.
- Following an evidentiary hearing before a different single member, the employee was awarded compensation (June 10, 1985).
- The award relied largely on a non-treating physician’s report and deposition testimony (Dr. Alan Balsam) opining that work stress caused or contributed to the coronary condition.
- The record also included deposition testimony from the treating cardiologist (Dr. Maximilliaan G. Kaulbach) and other medical evidence bearing on causation.
- On review, the reviewing board reversed and vacated the award, finding the medical evidence showed a natural progression of underlying disease unrelated to work effort.
- The employee appealed, challenging the reviewing board’s authority and the evidentiary basis for its reversal under the post-1985 statutory amendments.

## Issues

1. Whether, under G.L. c. 152, § 11C (as amended in 1985), the reviewing board could reverse a single member’s decision and make different factual findings on the same record.
2. Whether the reviewing board’s decision was based on an error of law, made upon unlawful procedure, or unsupported by substantial evidence.
3. Whether the reviewing board improperly disregarded the single member’s findings (including any credibility-based inferences) when resolving conflicting medical opinions.

## Decision

- The Supreme Judicial Court affirmed the reviewing board’s decision denying compensation.
- The reviewing board acted within its authority under G.L. c. 152, § 11C to reassess the evidentiary record and reach different factual conclusions.
- The reviewing board’s causation finding—natural progression of disease unrelated to work—was supported by substantial evidence, including the treating cardiologist’s deposition.
- The decision was not based on error of law and was not made upon unlawful procedure.
- Judicial review properly focused on the reviewing board’s findings, not the single member’s, and did not permit reweighing the evidence de novo.

## Legal Principles

- Under G.L. c. 152, § 11C, the reviewing board may make its own findings of fact and reassess the weight of evidence, including competing medical opinions, if its decision is supported by substantial evidence and reached through lawful procedure.
- In reviewing workers’ compensation decisions, courts review the reviewing board’s decision for substantial evidence and legal or procedural error; they do not independently reweigh the evidence.
- Where the record consists largely of depositions and documentary medical evidence, the reviewing board may evaluate that record and choose among conflicting expert views without deferring to the single member’s inferences.
- A compensation claim fails when the reviewing board permissibly finds, on substantial medical evidence, that the employee’s condition reflects the natural progression of a preexisting disease rather than work-related aggravation.

## Conclusion

The court upheld the reviewing board’s power under the amended workers’ compensation statute to independently evaluate the record and reverse a compensation award when substantial evidence supports a finding that the employee’s heart condition was not causally related to work.


Lettich’s Case, 530 N.E.2d 159 (Mass. 1988)