Utah Court of Appeals

Must medical panels address contrary opinions in workers' compensation cases? C.R. England Inc. v. Labor Commission Explained

2023 UT App 40
No. 20210819-CA
April 20, 2023
Affirmed

Summary

C.R. England challenged the Labor Commission’s decision to admit a medical panel report recommending cognitive behavioral therapy for an injured worker. The medical panel’s report contradicted C.R. England’s medical examiner but did not specifically address or explain the disagreement with that contrary opinion.

Analysis

In C.R. England Inc. v. Labor Commission, the Utah Court of Appeals clarified the evidentiary standards for medical panel reports in workers’ compensation proceedings, addressing whether medical panels must explicitly discuss contrary medical opinions.

Background and Facts

Suzi Poyfair suffered a work-related injury and sought workers’ compensation benefits. The case was referred to a medical panel, which reviewed all medical records including a report from C.R. England’s medical examiner, Dr. Theiler. Dr. Theiler opined that Poyfair could return to sedentary work for 40+ hours per week. However, the medical panel reached the opposite conclusion, finding Poyfair had a temporary inability to perform basic work and recommending cognitive behavioral therapy among other treatments. The panel did not specifically discuss or explain its disagreement with Dr. Theiler’s report.

Key Legal Issues

C.R. England objected to the medical panel’s report on two grounds: (1) the panel’s use of the word “may” regarding cognitive behavioral therapy indicated the recommendation was not made to the standard of reasonable medical probability; and (2) the panel failed to discuss Dr. Theiler’s contrary opinion and explain its disagreement.

Court’s Analysis and Holding

The court applied an abuse of discretion standard to review the Labor Commission’s decision to admit the medical panel report. Regarding the cognitive behavioral therapy recommendation, the court examined the report “as a whole” and found it adequately supported by evidence-based guidelines and medical reasoning, despite the panel’s use of “may.” On the second issue, the court held that medical panels are not required to explicitly address contrary medical opinions, as their role is to provide evidence to assist the Commission, not serve as decision makers.

Practice Implications

This decision reinforces that medical panels have significant latitude in how they present their findings. Practitioners should focus challenges on substantive medical inadequacies rather than procedural objections about failure to address contrary evidence. The administrative law judge remains responsible for weighing all medical evidence, including opinions not specifically discussed by the panel.

Original Opinion

Link to Original Case

Case Details

Case Name

C.R. England Inc. v. Labor Commission

Citation

2023 UT App 40

Court

Utah Court of Appeals

Case Number

No. 20210819-CA

Date Decided

April 20, 2023

Outcome

Affirmed

Holding

A medical panel is not required to specifically address or explain disagreement with contrary medical opinions in its report, and the panel’s recommendation must be read as a whole to determine if based on reasonable medical probability.

Standard of Review

Abuse of discretion for the Labor Commission’s refusal to exclude a medical panel report

Practice Tip

When challenging medical panel reports, focus on substantive medical inadequacies rather than procedural objections about failure to address contrary opinions, as panels are not required to explain disagreements with other medical evidence.

Need Appellate Counsel?

Lotus Appellate Law handles appeals before the Utah Court of Appeals, Utah Supreme Court, California Court of Appeal, and the United States Court of Appeals for the Tenth Circuit.

Related Court Opinions

    • Utah Court of Appeals

    Innerlight, Inc. v. The Matrix Group, LLC

    August 30, 2012

    A party that successfully obtains dismissal of an action on forum selection grounds is entitled to attorney fees under a contractual provision awarding fees to the prevailing party in ‘any action,’ regardless of whether the dismissal constitutes a determination on the merits.
    • Attorney Fees
    • |
    • Contract Interpretation
    • |
    • Jurisdiction
    Read More
    • Utah Supreme Court

    Jensen v. IHC Hospitals, Inc.

    April 4, 1997

    The two-year medical malpractice statute of limitations governs wrongful death claims arising from medical malpractice and begins running when the patient discovers or should have discovered the underlying injury, but fraudulent concealment issues present genuine disputes of material fact precluding summary judgment.
    • Standard of Review
    • |
    • Statutory Interpretation
    • |
    • Tort Law and Negligence
    Read More
About these Decision Summaries

Lotus Appellate Law publishes these summaries to keep practitioners informed — not as legal advice. Each case turns on its own facts. If a decision here is relevant to your matter, we’re happy to discuss it.