City of Owensboro v. Adams

Gary Adams (plaintiff) was employed by the City of Owensboro, Kentucky (the city) (defendant). On May 15, 1987, Adams and a coworker were exposed to toxic methane gas while cleaning the city’s sewer line. Adams’s coworker died, and Adams lost consciousness and hit his head. Adams suffered neck and facial pain after the fall but was able to continue working for the city. Adams sought workers’-compensation benefits for a partial disability, and he settled his claim for $6,125 in July of 1989. However, over the next several years, Adams continued to experience facial pain. Adams was diagnosed with bilateral trigeminal neuralgia and underwent 14 surgeries to try to treat the condition. The surgeries were ultimately unsuccessful, and Adams stopped working in September of 2000 due to his severe pain. In December of 2000, Adams filed a motion to reopen his workers’-compensation claim. In proceedings before an administrative-law judge (ALJ), the neurologist who diagnosed Adams’s condition gave medical expert testimony about trigeminal neuralgia. The neurologist testified that he had treated around 1,000 trigeminal neuralgia patients, and he opined that Adams’s neuralgia was caused by the 1987 methane incident. There had never been another documented case of neuralgia caused by toxic-gas exposure, and four other experts opined that Adams’s condition was instead most likely caused by relapsing multiple sclerosis. The neurologist admitted that multiple sclerosis was the only well-documented cause of trigeminal neuralgia, but he rejected multiple sclerosis as the cause of Adams’s neuralgia based on diagnostic testing that ruled out other possible causes and on the gradual onset of Adams’s condition beginning shortly after the methane exposure. The ALJ awarded Adams benefits based on the neurologist’s opinion that the methane exposure caused Adams’s disability. The ALJ found that the neurologist’s opinion was reliable and admissible under the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) because the opinion was based on the neurologist’s diagnostic testing and expertise. The Workers’ Compensation Board and an appellate court affirmed the award, and the city appealed to the Kentucky Supreme Court.