Mahaffey v. State ex rel. Wyoming Workers' Safety & Compensation Division

Summary

The Wyoming Supreme Court reviewed an administrative decision awarding Donald Dial permanent partial disability benefits under the Wyoming Workers' Safety and Compensation Act. The court held that substantial evidence supported the Office of Administrative Hearings' determination that Dial was unable to obtain employment at a wage at least 95% of his pre-injury earnings. The court reversed the district court and remanded with directions to reinstate the benefits award.

Holdings

1. Substantial evidence supported the OAH's finding that Dial was unable, because of his work-related injury, to obtain employment at a wage at least 95 percent of his pre-injury earnings.
2. The district court improperly substituted its judgment for that of the OAH, which was the fact finder responsible for weighing the evidence and determining witness credibility.

Questions Presented

1. Whether substantial evidence supported the OAH's determination that Dial was unable, because of his work-related injury, to return to employment paying at least 95 percent of his pre-injury wage.
2. Whether the OAH acted arbitrarily, capriciously, abused its discretion, or acted contrary to law in awarding permanent partial disability benefits.
3. Whether the district court improperly substituted its judgment for that of the administrative fact finder.

Disposition

reversed_and_remanded