The Louisiana Court of Appeal recently upheld a decision denying Rae Rodriguez's claim for workers' compensation benefits against Willis-Knighton Health. The court ruled that Rodriguez forfeited her rights to these benefits due to untruthful statements she made on employment questionnaires regarding previous injuries. This decision is significant as it emphasizes the importance of honesty in workers' compensation claims and the potential consequences of failing to disclose prior injuries.
The case, Rae Rodriguez v. Willis Knighton Health, was filed under docket number 57,022-WCA. Rodriguez was employed by Willis-Knighton on September 26, 2022. Before starting her job, she underwent a pre-employment physical and completed two questionnaires that asked about any previous work-related injuries. Rodriguez answered “No” to questions about past accidents and recommended surgeries, which later became the focus of the dispute.
The incident that led to Rodriguez's claim occurred on June 12, 2024, when she tripped over a car seat strap and fell, injuring her lower back, neck, and right arm. After reporting the injury, she was diagnosed with work-related injuries and prescribed treatment. However, shortly after, her employer’s claims consultant filed a Notice of Controversion, leading to the termination of her benefits.
Rodriguez's claim was denied after a trial held on July 30, 2025. The workers’ compensation judge (WCJ) found that she had made false statements on the questionnaires regarding her medical history, which led to the forfeiture of her benefits. The judge noted that Rodriguez had previously suffered injuries while working at another job and had received medical recommendations for surgery, which she failed to disclose.
The court's ruling was based on Louisiana Revised Statute 23:1208.1, which states that employees must answer truthfully about prior injuries. The court emphasized that Rodriguez's failure to disclose her past injuries prejudiced Willis-Knighton's ability to seek reimbursement from the second injury fund, which is designed to protect employers from excess liability when hiring individuals with preexisting conditions.
Judge Marcotte, along with judges Pitman and Ellender, affirmed the WCJ's ruling, stating, “We cannot say that the WCJ committed manifest error in finding that Rodriguez forfeited her rights to workers’ compensation benefits by violating La. R.S. 23:1208.1.” This ruling underscores the court's commitment to enforcing the law regarding truthful disclosures in workers' compensation cases.
The implications of this ruling are significant for both employees and employers. It serves as a reminder for employees to be honest when filling out medical questionnaires, as any inaccuracies can lead to the forfeiture of benefits. Employers, on the other hand, can take this ruling as a precedent to ensure that they are diligent in their hiring processes and in verifying the medical histories of potential employees.
Moving forward, this decision may influence how workers' compensation claims are handled in Louisiana. Employees may become more cautious about their disclosures, while employers may implement stricter protocols for assessing potential hires. The ruling also sets a precedent for future cases involving similar issues of disclosure and the consequences of untruthful statements.
As for what’s next, it is unclear whether Rodriguez will appeal this decision. The court's ruling allows for an application for rehearing within the timeframe set by Louisiana law, but details regarding any potential appeal were not available in the court filing. This case highlights the complexities of workers' compensation claims and the importance of transparency in the process.