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Villegas v. GC Landscaping/Special Fund - Memorandum Decision - Arizona Court of Appeals - April 24, 2025

  • Writer: Christopher S. Norton, Esq.
    Christopher S. Norton, Esq.
  • Jul 5
  • 2 min read
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Facts: Manuel Villegas, an employee of GC Landscaping, sustained injuries in 2018 after falling at a worksite. ​ GC Landscaping was uninsured, and the Industrial Commission of Arizona (ICA) Special Fund Division stepped in to manage the claim. ​ Initially, the ICA denied compensability but later found the claim compensable in 2019. ​ Villegas received active treatment for aggravated degenerative lower back conditions caused by the fall, as determined by his treating physician, Dr. Sanjay Patel. ​ In 2021 and 2022, the ICA rejected attempts to close the claim, relying on Dr. Patel’s opinion that Villegas was not medically stationary and required ongoing care. ​ However, in 2023, the ICA closed the claim, concluding Villegas had no permanent impairment and did not require supportive care, based on the opinion of Dr. James Maxwell, who diagnosed a resolved lumbar sprain/strain. ​ Villegas challenged this decision, arguing that Dr. Patel’s earlier diagnosis should preclude reliance on Dr. Maxwell’s opinion. ​


Issue(s):

  1. Does Dr. Patel’s earlier diagnosis of Villegas’s injury have preclusive effect on subsequent determinations regarding permanent impairment? ​

  2. Did the Administrative Law Judge (ALJ) err in adopting Dr. Maxwell’s opinion over Dr. Patel’s? ​


Holding: The Arizona Court of Appeals affirmed the ICA’s decision, holding that Dr. Patel’s diagnosis of the nature and causation of Villegas’s injury does not preclude subsequent determinations regarding permanent impairment. ​ The ALJ did not abuse its discretion in adopting Dr. Maxwell’s opinion, as resolving conflicts in expert testimony is within the ALJ’s purview. ​


Key Takeaways:

  1. Workers’ compensation claims are administered sequentially, and determinations regarding compensability, medical stationary status, and permanent impairment are separate and distinct. ​

  2. A prior diagnosis of injury and causation does not preclude later determinations about permanent impairment or supportive care. ​

  3. The ALJ has discretion to resolve conflicting expert opinions, and appellate courts will defer to the ALJ’s factual findings unless there is an abuse of discretion. ​

  4. Competent medical testimony, even if conflicting, can form the basis for an ALJ’s decision. ​



 
 
 

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