Case File
Because substantial credible evidence supported the compensation judge’s finding that the work injury exacerbated the worker’s knee symptoms, the Appellate Division affirmed an award of medical and temporary disability benefits.
Case
Munoz v. Costco, No. A-3829-24 (N.J. Super. Ct. App. Div. 08/12/26, unpublished)
What Happened?
A part-time Costco worker injured his right knee helping a customer lift a generator into a truck. The worker immediately reported the injury to a manager and received treatment from several doctors. The worker was diagnosed with a right knee medial meniscal tear and extensive chondromalacia of the patellofemoral trochlear groove.
The worker underwent surgery, and the surgeon cleared the worker to return to work on “light duty” and then cleared him to work full duty.
Three days after returning to full-duty status, the worker reported difficulty working and swelling in his knee. Due to pain, the worker resigned from Costco and applied for workers’ compensation benefits.
During the workers’ compensation hearing, the worker reported that his right knee would regularly “blow up” and “get swollen” while working and that after he finished his shift, he was unable to do even simple activities like climbing the steps to his home or going food shopping. Additionally, the worker testified that knee swelling occurred regularly while working. He also testified that he resigned solely because of the knee condition. He testified that managers knew he was leaving because of his knee problems. Additionally, he sought less physically demanding work before resigning.
Costco paid the worker temporary disability benefits for a period, and the worker sought temporary and/or medical benefits from his resignation forward. The dispute in the case concerned entitlement to continuing medical treatment and TTD after the worker resigned and after he had already been released to full duty
Based on another physician’s opinion that the worker’s injury likely “exacerbated the pain” and “activated his symptoms” in the patellofemoral compartment, the compensation court granted the worker’s motion and ordered Costco to pay TTD until the worker was returned to full duty work status.
Costco appealed, arguing that the compensation court erred in discounting the surgeon’s opinion that the work injury did not aggravate, accelerate, or exacerbate the worker’s underlying knee condition.
Rule of Law
Under New Jersey workers’ compensation law, a judge of compensation is not bound by the conclusional opinions of any one or more, or all of the medical experts. The judge is considered to have expertise with respect to weighing the testimony of competing medical experts and appraising the validity of the petitioner’s compensation claim. That the judge gave more weight to the opinion of one physician as opposed to the other provides no reason to reverse the judgment.
What the Court Said
The court upheld the compensation court’s decision to side with another doctor’s opinion over that of the surgeon’s.
“The credibility determinations are well-supported by substantial credible evidence in the record,” the court wrote.
In particular, the court highlighted that the compensation judge cited:
+ Knee MRI and X-rays.
+ Testing for the knee.
+ All of the experts were of the opinion that the worker was unable to work full duty.
Verdict: Finding that the compensation court’s determinations were not arbitrary, unreasonable, or capricious, the court affirmed its decision.
Takeaway
This decision underscores the highly deferential standard of review applied to workers’ compensation judges in New Jersey. When a compensation judge provides a reasoned basis for crediting one medical expert over another, the Appellate Division is unlikely to disturb those findings on appeal.
