Gray v. State of Wyoming
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In the State of Wyoming, an employee, James Gray, was injured in a work-related accident. He applied for permanent total disability benefits (PTD benefits) through the Wyoming Workers’ Safety and Compensation Division (Division). The Medical Commission found Gray eligible for PTD benefits under the odd lot doctrine. However, the issue of whether a physician’s certification was needed for PTD benefits in odd lot cases was deferred. The Office of Administrative Hearings (OAH) determined that without a physician’s certification, PTD benefits could not be awarded in an odd lot case and denied Gray’s claim. This decision was upheld by the district court.
Gray appealed to the Supreme Court of Wyoming, which reversed the lower courts' decisions. The Supreme Court held that a physician’s certification of non-medical matters is not a prerequisite to award PTD benefits through the common law odd lot doctrine. The odd lot doctrine allows a worker to obtain PTD benefits when they are not actually permanently totally disabled but are rendered unemployable due to their disability and other factors such as mental capacity, education, training, and age. The Supreme Court found that in instances where a claimant cannot meet the statutory definition of permanent total disability because of their physical impairment alone, the odd lot doctrine applies. In such cases, the claimant's impairment coupled with vocational factors and the type of work available in a community renders that claimant unable to work at any gainful occupation for which they are reasonably suited by experience and training. The case was remanded for entry of an order consistent with this opinion.
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