Minor v. SAIF

Worker's Compensation Board orders are reviewed as provided in ORS 183.482(7) and (8). Courts review for substantial evidence, which "exists to support a finding of fact when the record, viewed as a whole, would permit a reasonable person to make that finding." ORS 183.482(8)(c). In reviewing for substantial evidence, a court must also determine whether the board's analysis comports with substantial reason. To satisfy that requirement, the board must "provide a rational explanation of how its factual findings lead to the legal conclusions on which the order is based." Arms v. SAIF, 268 Or App 761, 767, 343 P3d 659 (2015).

Plaintiff appealed an order of the Workers' Compensation Board that upheld the denial of her occupational disease claim for post-traumatic stress disorder. Plaintiff assigned error to the Board's rejection of her psychiatrist's opinion, for failing to fully address Plaintiff's "non-traumatic" stressors. On appeal, Plaintiff argued that those stressors were irrelevant to her psychiatrist's specific diagnosis of PTSD and as a result, substantial evidence and substantial reason do not support the board's finding that the psychiatrist's opinion was unpersuasive. In response, Defendant argued that the board adequately explained its grounds for finding the psychiatrist unpersuasive. Courts review for substantial evidence, which "exists to support a finding of fact when the record, viewed as a whole, would permit a reasonable person to make that finding." ORS 183.482(8)(c). In reviewing for substantial evidence, a court must determine whether the board's analysis comports with substantial reason. To satisfy that requirement the board must "provide a rational explanation of how its factual findings lead to the legal conclusions on which the order is based." Arms v. SAIF, 268 Or App 761, 767, 343 P3d 659 (2015). The Court of Appeals held that substantial reasons did not support the board's decision to discount the psychiatrist's opinion. Reversed and remanded.