Butts v. Alaska Department of Labor & Workforce DevelopmentAnnotate this Case
Office worker Sallyanne Butts (f/k/a Decastro) fell from her chair onto her hands and left knee. She initially suffered left knee symptoms and later developed right knee problems and lower back pain that she alleged arose from the fall. She argued the Alaska Workers’ Compensation Board erred when it performed its presumption analysis and when it awarded compensation for her left knee and back for only a limited period of time following the accident. The Alaska Supreme Court concluded: the Board appropriately considered the knee injuries and the back injury as distinct injuries and applied the presumption analysis accordingly; that the Board properly relied on the conflicting medical evidence to make its own legal decision about which of Butts’s conditions were compensable; and that the Board was not required to award compensation for knee replacement surgeries performed five years after the accident. The Court therefore affirmed the Alaska Workers’ Compensation Appeals Commission’s decision affirming the Board.