McMasters v. State ex rel. Workers’ Safety & Comp. Div.

Jimmie McMasters was working as an HVAC journeyman when he fell from a beam to a concrete floor and suffered an injury. McMasters applied for permanent total disability benefits claiming a total disability. The Wyoming Workers' Safety and Compensation Division denied the application. The Division did not dispute that McMasters could not return to work but instead contended that McMasters' failure to obtain alternative employment was due to a preexisting psychological condition and a poor effort to find work. The Medical Commission agreed and upheld the denial of benefits. The district court affirmed. The Supreme Court reversed, holding (1) McMasters established a prima facie case under the odd lot doctrine when he showed he could not return to his former employment, and the combination of his psychological and physical conditions precluded alternative employment; (2) the burden thereafter shifted to the Division to show that light work of a special nature, which McMasters could perform, was available; and (3) the Division did not meet its burden. View "McMasters v. State ex rel. Workers' Safety & Comp. Div." on Justia Law