JCC Denies Lumbar Benefits After Applying Res Judicata to Disc Claims

In Bradley v. Polk County School Board, OJCC Case No. 23-022554BJA, the claimant sought TTD, TPD, and a return appointment with Dr. Weber after a September 1, 2023 low-back incident involving a truck seat. The disputed petition covered benefits from October 22, 2024 through April 21, 2026, plus related penalties, interest, fees, and costs.

Judge Brian J. Anthony treated the central medical-causation issue as already decided. A prior compensation order had found only a temporary exacerbation of a preexisting degenerative low-back condition, and had rejected compensability of the L3-4 and L5-S1 disc findings. The JCC again rejected the claimant's IME opinion from Dr. Inga and credited Dr. Weber's testimony that any surgery and impairment related to underlying lumbar disease, not the work accident.

The order denied TTD for lack of credible proof of a no-work status, found TPD through March 10, 2025 moot because payout records showed those benefits, penalties, and interest had been paid, and denied later TPD after MMI. The JCC also denied further treatment with Dr. Weber, penalties, interest, attorney's fees, and costs, while expressly relying on res judicata to prevent relitigation of the lumbar disc claims.

Source: Compensation Order