AZ Patios v. Serrano - Memorandum Decision - Arizona Court of Appeals - June 5, 2025

Facts: Christian Serrano, an employee of AZ Patios, fell off a ladder at work, injuring his lower back and left ankle. ​ He underwent lumbar surgery and was declared at maximum medical improvement by his treating doctors. ​ However, Serrano challenged the closure of his workers' compensation claim, arguing he required further active medical treatment for his lower back condition. ​ At the Industrial Commission of Arizona (ICA) hearing, two orthopedic spine surgeons provided conflicting testimony. ​ Dr. Khalsa supported Serrano’s claim, diagnosing lumbar radiculopathy and recommending further surgery, while Dr. Maric opined that Serrano had reached maximum medical improvement and required no further treatment. The Administrative Law Judge (ALJ) found Dr. Khalsa’s testimony more persuasive and ruled in favor of Serrano, concluding he was not medically stationary and required additional treatment.

Issue(s):

1. Did the ALJ err in resolving the conflict between the medical opinions of Dr. Khalsa and Dr. Maric? ​

2. Was the evidence sufficient to support the finding that Serrano’s current lower-back condition was caused by his work injury? ​

   
   

Holding: The Arizona Court of Appeals affirmed the ICA’s award, holding that the ALJ’s resolution of conflicting medical opinions was reasonably supported by the evidence and did not constitute an abuse of discretion. ​

Key Takeaways:

1. The claimant bears the burden of proving entitlement to continued workers’ compensation benefits, including demonstrating that their condition is not medically stationary. ​

2. When medical causation is not apparent to a layperson, expert testimony is required to establish the connection between the injury and the condition. ​

3. The ALJ has the authority to resolve conflicts in medical evidence, assess witness credibility, and draw reasonable inferences. ​

4. The appellate court does not re-weigh evidence but affirms decisions that are reasonably supported by the evidence. ​

   
   

URL to Read Full Decision: 1 CA-IC 24-0045 AZ Patios Secura v. Serrano.pdf