In the very recent Pennsylvania Commonwealth Court case, Lawry v. County of Butler (Workers' Compensation Appeal Board), (Pa. Commw. No. 593 C.D. 2022, filed March 6, 2024), the court accepted the the claimant's articulation of the one issue before the court as "whether the board's decision violated long-standing and fundamental workers' compensation principles and, therefore, should be reversed." Given that this presentation of the issue is a bit odd and vague, but clearly of existential significance to the practice of workers' compensation, it is only natural to want to learn more. To begin with, it is not clear whether the claimant was represented by counsel before the court, as the court noted that the claimant acted pro se before both the workers' compensation judge (WCJ) and the board. Either way, the claimant did an excellent job of demonstrating the error in the board's opinion that had reversed her success before the WCJ in a termination petition. As the court determined that the case was "precedential" a review is warranted.

By way of background, the claimant sustained and injury that was described as a "right thumb strain/sprain" in June 2009. In July 2011, the workers' compensation judge (WCJ) expanded the description of injury to include "right ulnar collateral ligament tear and reflex sympathetic dystrophy (RSD)/complex regional pain syndrome (CRPS)" and also denied the employer's first termination petition. The employer went on to file three additional termination petitions, each of which were denied by the same WCJ. The most recent petition, which was the subject of this appeal, was denied in July 2021. While the WCJ did find the claimant fully recovered from the original right thumb strain/sprain and the added right ulnar collateral ligament tear, he determined that the employer failed to meet its burden that the claimant was fully recovered from the other expanded injuries of RSD/CRPS. In doing so, the WCJ rejected the defense doctor's opinion, in part due to what he determined was the doctor's failure to reference the "Budapest criteria" for diagnosing RSD/CRPS referenced in Kesserling v. Workers' Compensation Appeal Board (Pocono Medical Center), 247 A.3d 1194 (Pa. Commw. 2021).