In the Matter of the Claim of Veronica Garland
Claimant Veronica Garland, a correction officer, appealed a Workers' Compensation Board decision from November 2, 2020, which denied her a schedule loss of use (SLU) award. Garland had established claims for work-related back, shoulder, elbow, wrist, knee, and foot injuries from incidents in 2011 and 2009. The 2011 claim involved protracted litigation regarding permanency and loss of wage-earning capacity. Following the Matter of Arias v City of New York decision, a WCLJ recognized Garland's potential entitlement to an SLU award. The WCLJ credited the employer's medical examiner, Thomas Patrick Nipper, who found no increase in right arm SLU beyond a previous 22.5% finding and no permanency for other injuries. The Board affirmed this, leading to Garland's appeal. The Appellate Division affirmed the Board's decision, stating that the Board has discretion to resolve conflicting medical opinions and is not bound by prior WCLJ credibility determinations on different issues.