McClain v. Eagle Intermodal Services, Inc., No. WC25-6626 (WCCA May 27, 2026).
On August 1, 2007, Employee Danny McClain sustained an admitted right wrist injury while throwing heavy semi-tractor trailer tires. The Employee underwent three right wrist surgeries between 2008 and 2010 (arthroscopic repair, fusion surgery, and exploratory nerve resection) due to chronic pain. Medical providers noted potential complex regional pain syndrome (CRPS) symptoms as early as 2008, but the Employee’s primary provider and IMEs for the Employer and Insurer denied the diagnosis. A March 2011 Functional Capacity Evaluation (FCE) limited the Employee to lifting a maximum of five pounds rarely and noted consequential left-hand weakness from overcompensation.
On July 27, 2011, the parties entered into a $200,000 settlement closing out all future benefits except for medical care related to the right wrist, a claimed consequential left wrist injury, and gastrointestinal issues. The parties explicitly stipulated that the Employee was permanently and totally disabled (PTD) as of January 27, 2010. A subsequent June 19, 2012 stipulation resolved some outstanding medical bills and penalties for late payment.
The Employee continued to treat in the years after the stipulations and continued to complain of symptoms in his right wrist, left wrist, and then later his right elbow and right shoulder. He was formally diagnosed with right upper extremity CRPS in September 2016 and underwent stellate ganglion blocks. He also developed a full-thickness right shoulder rotator cuff tear and underwent surgery in 2019.
The Employee filed a Claim Petition in 2017, claiming permanent total disability, permanent partial disability, and various medical benefits. The Claim Petition was stricken from the active trial calendar several times over the following years, but never formally dismissed. In 2025, the Employee filed a Petition to Vacate, arguing that the 2011 and 2012 awards should be vacated for cause under Minn. Stat. 176.461 due to a substantial change in medical condition that was clearly unanticipated at the time of settlement. As evidence, they pointed to his severe CRPS, subsequent right shoulder surgeries, and increased functional disability. The Employer and Insurer denied that a substantial change occurred as CRPS and other upper extremity symptoms were already documented or suspected prior to the settlements. Further, the Employer and Insurer argued that because the Employee already stipulated to being permanently and totally disabled in 2011, he cannot be considered “more” permanently and totally disabled to justify a substantial change in condition.
The parties engaged in oral arguments before the WCCA. Attorney Sydney St Germain argued before the court on behalf of the Employer and Insurer.
In its decision, the WCCA noted various conflicting evidence, especially among the medical experts, regarding the alleged CRPS, other alleged body parts, and permanent partial disability. The WCCA noted it “cannot address the employee’s petition to vacate the awards not the employer and insurer’s counterarguments until factual findings are made on the nature of the employee’s current medical conditions including diagnoses, PPD ratings, reasonable and necessary medical treatment, and payment for the treatment.” The court exercised its authority under Minn. Stat. 176.521, subd. 3 and referred the case to the chief judge of CAH for assignment to a compensation judge for a full evidentiary hearing and for specific factual findings.
Takeaway: In cases where there are significant factual disputes, particularly in matters with conflicting expert medical opinions, the WCCA has the statutory authority to refer matters to CAH for factual findings.