J R Schugel Trucking Inc. v. Logan

There was evidence supporting the State Board of Workers' Compensation Appellate Division's decision finding that the claimant was not entitled to ongoing medical benefits, and the superior court thus erred in setting aside that award.

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Donna Logan, a North Carolina resident, was injured in August 2013 while working in Georgia for her employer, JR Schugel Trucking, Inc., located in Minnesota. Logan received workers’ compensation benefits under Minnesota law until the benefits were suspended in September 2013 due to lack of evidence of disability. In October 2013, Logan filed a workers’ compensation claim in Georgia seeking recommencement of income benefits and medical care under Georgia law. JR and its insurer, Great West Casualty Co., controverted the claim on the basis that there was no evidence Logan suffered from any continued disability, and that she had no need for ongoing medical treatment. In this opinion, we refer to the employer and insurer jointly as JR. An administrative law judge ALJ in the Trial Division of the State Board of Workers’ Compensation ruled that, although Logan had no continuing disability from the injury, she was still entitled to ongoing medical benefits. Pursuant to JR’s appeal, the Board’s Appellate Division affirmed the ALJ’s ruling that there was no disability, but substituted alternative findings and ruled that Logan was not entitled to ongoing medical benefits. On appeal from the Appellate Division, the Fulton County Superior Court entered an order setting aside the Appellate Division decision as contrary to law under OCGA § 34-9-105 c 5. JR appeals from the Superior Court order, and for the following reasons we reverse.

Based on evidence presented at the June 2014 hearing on Logan’s claim, the ALJ issued an award finding that Logan failed to prove any continuing disability related to the August 2013 injury and was not entitled to any workers’ compensation income benefits under Georgia law. But despite finding no continuing disability, the ALJ ruled that Logan nevertheless remained entitled to ongoing medical benefits for the injury.

J R Schugel Trucking Inc. v. Logan

There was evidence supporting the State Board of Workers' Compensation Appellate Division's decision finding that the claimant was not entitled to ongoing medical benefits, and the superior court thus erred in setting aside that award.

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