Howard University Hospital v. D.C. Department of Employment Services
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Dennis Neal, a heating, ventilation, and air conditioning technician at Howard University Hospital, was injured on the job when a ladder gave way beneath him. He experienced pain and underwent spinal surgery. After attempting to return to work and experiencing further pain, he quit and sought reinstatement of his disability benefits and vocational rehabilitation services. The hospital terminated his benefits when he accepted new employment but quit after four days due to physical discomfort from long drives and job duties.
An Administrative Law Judge (ALJ) granted Neal's claim for reinstatement of benefits and services, and the Compensation Review Board (CRB) affirmed. The hospital appealed, arguing that the CRB lacked substantial evidence to support its findings that Neal did not voluntarily limit his income and did not fail to cooperate with vocational rehabilitation. The hospital contended that the ALJ and CRB ignored critical testimony from witnesses.
The District of Columbia Court of Appeals reviewed the case and found that the CRB's decision was supported by substantial evidence. The court noted that the ALJ's findings were based on credible evidence, including medical evaluations and Neal's testimony about his physical limitations and the nature of the job duties at his new employment. The court also found that Neal had cooperated with vocational rehabilitation services and had demonstrated a willingness to continue doing so.
The court held that the CRB's decision flowed rationally from the facts and was supported by substantial evidence. The court affirmed the CRB's decision to reinstate Neal's temporary total disability benefits and vocational rehabilitation services.
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