Wilson, Scott v. American Paper & Twine Co.
The Court held an Expedited Hearing to determine if Mr. Wilson was entitled to medical treatment for carpal/cubital tunnel syndrome, which he alleged was a natural consequence of a compensable left-shoulder injury and subsequent rotator cuff repair surgery. Initially, Dr. Shaffer opined the condition was not attributable to the work injury. However, Dr. Paul Abbey, a hand specialist, diagnosed both carpal and cubital tunnel syndrome, stating it resulted from the prior rotator cuff surgery and was a contributing factor. Applying the 'direct and natural consequences rule,' the Court found Mr. Wilson's carpal/cubital tunnel syndrome was likely a natural consequence of his primary compensable shoulder injury, despite Dr. Abbey's inability to state it was greater than fifty percent responsible. Consequently, the Court granted benefits, ordering American Paper to continue providing medical treatment, including treatment with Dr. Abbey.