Missing findings concerning impact of settlement agreement earn remand

The Alabama Court of Civil Appeals reversed the trial court's judgment that the employer was responsible for medical benefits for treatment of the claimant's right knee. The trial court did not enter appropriate findings of fact concerning language in a settlement agreement that waived the claimant's right to future medical expenses for his knees. As a result, the Court of Civil Appeals returned the case for further proceedings.

Case name: Matthew's Masonry Co. v. Aldridge, No. 2070485 (Ala. Civ. App. 10/03/08).

What it means: Where the claimant and employer have entered into a settlement agreement, which includes a provision waiving the claimant's right to future medical benefits for a knee injury, the trial court must make specific findings concerning the effect the agreement has on a subsequent claim for such benefits.

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Summary: The claimant settled a workers' compensation claim involving his back. In the settlement agreement, his right to future medical benefits for treatment of his back injury was preserved. However, he waived any claim "for medical expenses in connection with his left knee and his right knee." The claimant contended that the employer was liable for treatment of a right knee condition that developed because of his low back injury, which altered his gait. The trial court agreed, holding the employer liable for treatment of the knee condition as long as the medical evidence linked the treatment to the accepted lower back condition. The Court of Civil Appeals reversed the trial court's judgment. Because the trial court did not address the effect of the specific language in the settlement agreement releasing the employer from liability for medical expenses related to the claimant's right knee, further findings of fact were warranted.

December 2, 2008

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