Workers' Compensation reinstated by Alaska Supreme Court
Traugott v. ARCTEC Alaska (June 12, 2020)
Joseph Traugott (“Traugott”) was an employee of ARCTEC Alaska (“ARCTEC”), working in remote sites in Alaska. He maintained heating and ventilation systems, which required him to move up and down ladders frequently. Traugott suffered from diabetes, considered a preexisting medical condition, which he disclosed during his preemployment physical examination. Despite this condition, Traugott was cleared to work for ARCTEC.
During the course of Traugott’s work with ARCTEC, he developed a severe infection in his foot, which eventually caused the complete degeneration of one of his ankle bones and required extensive surgery and treatment. Traugott subsequently could not return to work and brought a claim before the Alaska Workers’ Compensation Board (“Board”), which found that his disability and need for medical treatment were compensable. The Board’s decision was based on an expert medical opinion concluding that Traugott’s work was the sole cause of the acceleration of his condition, even if his work was not the most significant cause of his overall condition. ARCTEC appealed the decision to the Alaska Workers’ Compensation Appeals Commission (“Commission”).
The Commission functions similarly to a court of appeals in that it does not reweigh conflicting evidence, determine witness credibility, or evaluate competing testimonies, as those functions are reserved for the Board. Alaska law requires the Commission to uphold the Board’s findings of fact if the findings are supported by substantial evidence in light of the whole record. Substantial evidence is defined as “relevant evidence which a reasonable mind might accept as adequate to support a conclusion.” The Commission concluded that the Board’s decision was not supported by substantial evidence and reversed the Board’s decision. This appeal to the Alaska Supreme Court followed.
The Alaska Supreme Court (“Court”) reviews anew the Commission’s legal conclusions about whether substantial evidence supports the Board’s factual findings by independently reviewing the record and the Board’s factual findings. The Court found that not only did the Commission not consider the record as a whole, the Commission impermissibly reweighed the evidence to reach a different decision than the Board. The Board acts as the fact finder in Alaska Workers’ Compensation claims, and the legislature has stated that a factual finding by the Board is conclusive. This means that on appeal to the Commission, those facts should not be reexamined and reweighed if they are supported by “substantial evidence” in the entire record. This is analogous to the Court’s review of findings of fact from lower courts. In an appeal from the Commission to the Court, findings of fact are only overturned if they are clearly erroneous, and the Court is left with a definite conviction that the Commission erred.
The Court found that the Board acted appropriately when it decided Traugott’s claim. The Court’s review of the entire record led it to the conclusion that substantial evidence in the record supported the Board’s decision that Traugott’s work-related injury, and not his underlying condition, was the substantial cause of his disability and need for medical treatment. As a result, the Court overturned the Commission’s reversal of the Board’s ruling in Traugott’s favor and instructed the Commission to reinstate the Board’s order to compensate Traugott.
By Jenna Sutton