The Arkansas Court of Appeals has upheld a decision denying a workers' compensation claim from Amanda Engleman, who alleged shoulder injuries from a workplace incident at Washington Regional Medical Center. The ruling, delivered on October 28, 2026, is significant for workers seeking compensation for injuries sustained on the job, as it clarifies the burden of proof required to establish causation in such cases.

Engleman, who worked as an operating-room circulator, claimed she injured both shoulders while attempting to prevent a patient from falling off an operating table on June 2, 2023. The court's decision emphasizes the importance of demonstrating a clear causal link between a workplace incident and the injuries claimed, which Engleman failed to do according to the court.

Background

Amanda Engleman was employed at Washington Regional Medical Center, where her responsibilities included preparing operating rooms and assisting during surgeries. On June 2, 2023, she reported an incident where a patient began to slide off an operating table. Engleman went underneath the table to support the patient, during which she felt a pop in her left shoulder and experienced pain in both shoulders. She reported the incident immediately and sought medical attention.

After the incident, Engleman was treated at Conservative Care Occupational Health, where she was diagnosed with bilateral shoulder pain. Despite undergoing physical therapy and receiving steroid injections, her symptoms persisted. A series of medical evaluations revealed degenerative changes in her shoulders, but the connection between her workplace incident and her injuries became a point of contention.

Engleman's case was initially heard by an administrative law judge (ALJ), who ruled in her favor, stating that her injuries were compensable. However, Washington Regional Medical Center appealed this decision to the Arkansas Workers’ Compensation Commission, which reversed the ALJ's ruling, leading to Engleman's appeal to the Court of Appeals.

The Ruling

The Arkansas Court of Appeals affirmed the Workers’ Compensation Commission's decision to deny Engleman's claim. The court found that the Commission had substantial evidence to conclude that Engleman did not prove a causal connection between the June 2 incident and her shoulder conditions. The court noted, "the Commission expressly recognized that the objective-findings requirement applies only to the existence and extent of an injury."

Judge Robert J. Gladwin, writing for the court, highlighted that while Engleman provided some evidence in support of her claim, including the immediate reporting of the incident and subsequent medical treatment, the Commission was not obligated to accept this evidence as proof of causation. The court stated, "Engleman did not prove that the June 2, 2023 incident caused internal or external physical harm to the left shoulder or right shoulder." This finding was pivotal in the court's decision to uphold the denial of her claim.

Impact

This ruling has significant implications for workers' compensation claims in Arkansas. It underscores the necessity for claimants to provide clear and convincing evidence that links workplace incidents directly to their injuries. The court's decision reinforces that while medical evidence is crucial, it must be supported by a coherent narrative that establishes causation.

The case also highlights the role of credibility in workers' compensation claims. The Commission found Engleman not credible regarding the origins of her shoulder conditions, citing inconsistencies in her medical histories and testimony. This aspect of the ruling may influence how future claims are evaluated, particularly concerning the weight given to a claimant's testimony versus medical evidence.

What's Next

Engleman has the option to appeal the Court of Appeals' decision to the Arkansas Supreme Court, although it is unclear if she will pursue this route. There are no related cases pending that would directly affect this ruling. The outcome of this case may serve as a reference point for future workers' compensation claims, particularly those involving conflicting medical histories and the establishment of causation.