Valencia v. State of Wyoming, Ex Rel. Department of Workforce Services, Workers' Compensation Division
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During her employment as an administrative assistant, Judy Valencia suffered a right knee injury, which was covered by workers' compensation. Following the knee injury, she altered her gait and started experiencing pain in her left foot, ankle, and hammertoe. She sought workers' compensation benefits for these injuries, contending that they were causally related to her compensable right knee injury. However, the Wyoming Department of Workforce Services, Workers' Compensation Division denied the benefits, stating that the left foot, ankle, and hammertoe injuries were not related to the right knee injury. The Wyoming Medical Commission upheld the denial, and the district court affirmed the Commission's decision.
In the Supreme Court, State of Wyoming, Valencia argued that her left foot, ankle, and hammertoe injuries either constituted a second compensable injury caused by her right knee injury or materially aggravated her preexisting left foot conditions. The court upheld the lower courts' decisions, finding that Valencia failed to meet her burden of proving either claim. The court noted that Valencia's treating physicians did not opine that her right knee injury or altered gait materially aggravated her preexisting left foot conditions. Additionally, the court found that an independent medical examiner's opinion, which stated that the right knee injury did not cause any temporary exacerbations or permanent material aggravation of Valencia's preexisting left foot conditions, was supported by substantial evidence. Therefore, the court affirmed the denial of workers' compensation benefits for Valencia's left foot, ankle, and hammertoe injuries.
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