March 26, 2025 | Connecticut, USA — MedLegalNews.com — The Connecticut Supreme Court recently ruled that administrative law judges (ALJs) retain the discretion to award ongoing temporary partial incapacity benefits after a claimant reaches maximum medical improvement (MMI), even when permanent partial disability (PPD) benefits are available. This decision has significant implications for Connecticut workers compensation, reversing a 2024 Appellate Court ruling and a prior Compensation Review Board decision that favored the injured worker’s employer, the Department of Mental Health and Addiction Services.
The ruling highlights the importance of judicial discretion in assessing the unique circumstances of each workers’ compensation claim. By allowing ALJs to continue awarding temporary partial incapacity benefits post-MMI, the decision ensures that claimants with ongoing limitations or persistent symptoms receive appropriate financial support. Legal experts note that this flexibility can reduce disputes between employers and injured workers, promote fair outcomes, and reinforce the overall integrity of Connecticut workers compensation law.
Judicial Discretion in Workers’ Compensation
The Supreme Court found that the Connecticut workers compensation statute (§ 31-308) uses the term “may,” indicating that ALJs are not obligated to award PPD benefits after MMI. The court emphasized that the legislative amendments in 1993 did not alter the statutory language granting this discretion. Therefore, ALJs can choose to continue awarding temporary partial incapacity benefits instead of converting them to PPD benefits, depending on the claimant’s circumstances.
Case Background: Gardner v. Department of Mental Health
In April 2016, Beulah Gardner, employed as a forensic treatment specialist at Whiting Forensic Hospital, sustained a compensable wrist injury while restraining a patient. Despite multiple surgeries, her pain persisted. On May 21, 2020, her employer sought to discontinue her temporary partial incapacity benefits, claiming that Gardner had reached MMI and had a light-duty work capacity.
On June 2, 2021, the administrative law judge approved the request to convert her benefits. However, the judge believed he had no discretion to continue awarding temporary partial incapacity benefits. The Compensation Review Board and the Appellate Court upheld this decision, asserting that the 1993 legislative amendments removed judicial discretion.
Supreme Court Reinstates Discretion
Gardner appealed to the Connecticut Supreme Court, arguing that the statute’s clear language preserved ALJ discretion. She referenced the 1943 case Osterlund v. State, which confirmed this authority. The Supreme Court agreed, stating that legislative history should not create ambiguities when the statute’s language is clear.
The court concluded that the 1993 amendments did not affect an ALJ’s discretion. Consequently, the decision restores flexibility in determining appropriate benefits for claimants post-MMI.
Impact on Workers’ Compensation Claims
This ruling reinforces the authority of ALJs to evaluate individual cases and make informed decisions that best serve injured workers. By maintaining discretion, ALJs can tailor benefit awards to align with claimants’ ongoing work capacities and needs.
For the official opinion, visit the Connecticut Supreme Court Official Opinion page.
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FAQs: About Connecticut Workers Compensation
What did the Connecticut Supreme Court decide regarding workers compensation?
The court affirmed that ALJs have discretion to continue awarding temporary partial incapacity benefits even after claimants reach maximum medical improvement.
How does this ruling impact Connecticut workers compensation claims?
The decision allows ALJs to tailor benefits based on individual circumstances, providing flexibility and potentially more appropriate compensation for injured workers.
What is the significance of ALJ discretion in Connecticut workers compensation cases?
ALJ discretion ensures that benefit awards can reflect ongoing limitations or needs, rather than automatically converting temporary benefits to permanent partial disability payments.
Which cases influenced the Connecticut workers compensation ruling?
The Supreme Court referenced the 1943 case Osterlund v. State and legislative history to confirm that the 1993 amendments did not remove ALJ discretion.