MIRANDA v. RYDER SERVICES CORPORATION (2026)

An employee filed a workers’ compensation claim against his employer following an injury allegedly sustained while within the course and scope of his employment. After a one-day bench trial, the workers’ compensation judge rendered judgment in favor of the employee and against the employer. The employer appealed, and the employee filed an answer to the appeal. For the reasons that follow, we affirm the judgment of the workers’ compensation judge. In addition, the employee's answer to the appeal is granted in part and denied in part.

FACTS AND PROCEDURAL HISTORY

Plaintiff, Lajoal Miranda, was employed by Ryder Truck Rental, Inc. (“Ryder”) as a technician. Miranda claimed he suffered a workplace accident on April 22, 2024, near the end of his shift. According to Miranda, he was installing a sticker on an 18-wheeler while standing on an angled ladder with a platform on top. Miranda alleged he lost his balance on the ladder and began to fall, prompting him to brace his fall with his right arm against the 18-wheeler. Miranda asserted that he felt pain in his neck and shoulder immediately after the incident. According to Miranda, he reported the accident to his immediate supervisor, Brian Shally, and Shally's supervisor, Percy E. Caye, IV ¹ outside of Caye's office “a few minutes after [the accident] happened.” Miranda left work at the end of his shift shortly after the incident, and he did not return until May 1, 2024, “due to his ongoing symptoms.”

On May 8, 2024, Miranda completed an accident report for the incident. The next day, Ryder sent Miranda to Pelican Urgent Care and Occupational Health (“Pelican”) and paid for the visit. Pelican put Miranda on work restrictions. Ryder accommodated the work restrictions while continuing to pay Miranda the same wages he was earning before the accident, and Miranda continued to work the same number of hours he worked pre-accident.

On May 15, 2024, Miranda sought treatment for his injuries from a chiropractor (“Dr. Schulz”) at LA Health Solutions (“LA Health”), who diagnosed Miranda with cervical discopathy without myelopathy, cervical facet syndrome, sprain of ligaments of cervical spine, cervical strain, cervical radiculopathy, cervical segmental dysfunction, thoracic facet syndrome, thoracic sprain, strain of thoracic region, and thoracic sprain of right rotator cuff capsule. Dr. Schulz recommended that Miranda not return to work until he could be evaluated by a medical doctor. May 15, 2024, ultimately was Miranda's last day of work at Ryder.

The next day, May 16, 2024, Miranda's attorney sent Dr. Schulz's recommendation to Ryder along with a demand letter requesting payment of indemnity and medical benefits; authorization to treat with his choice of orthopedic surgeon; and preservation of any and all video footage from the date of the accident. Ryder's claims adjuster denied the claims that same day, noting “[t]here is no medical evidence that [the] alleged injury occurred at work.” Miranda sent a notice of disagreement to the adjuster and forwarded: (1) a May 20, 2024 report from Dr. Johnson, a medical doctor at LA Health, finding Miranda temporarily disabled; and (2) an affidavit from Caye, who attested Miranda told him he injured himself “while working on a trailer ․ in his capacity as a technician with Ryder Truck Rental, Inc.”

Miranda filed a disputed claim for compensation on June 7, 2024, against Ryder and its insurer.² Therein, Miranda sought wage benefits, temporary total disability status, penalties, and attorney's fees. Ryder answered Miranda's disputed claim for compensation on June 28, 2024, and denied that Miranda suffered a work accident during the course and scope of his employment with Ryder. Ryder also asserted that it was entitled to credits and offsets against compensation benefits. Thereafter, Miranda supplemented his disputed claim for compensation to add a claim for denial of continued medical care.

The matter proceeded to trial before a workers’ compensation judge (“WCJ”) on March 31, 2025. At the conclusion of the presentation of evidence, the WCJ took the matter under advisement and ordered the parties to submit post-trial briefs. The WCJ ultimately issued a final judgment and accompanying reasons for judgment on June 23, 2025. The WCJ rendered judgment in favor of Miranda and against Ryder, finding that Miranda: (1) was an employee of Ryder when he injured himself on April 22, 2024, while “in the course and scope of his employment”; (2) sustained injuries as a result of the April 22, 2024 accident; (3) sustained injuries that necessitated medical care; (4) was temporarily totally disabled as a result of the April 22, 2024 accident from May 15, 2024, through July 30, 2024; (5) had an average weekly wage of $1,280.00 (corresponding to a workers’ compensation rate of $816.00 per week); and (6) is entitled to supplemental earnings benefits (“SEB”) from July 31, 2024, through the date of trial. The WCJ ordered Ryder to pay the following amounts to Miranda: temporary total disability benefits (“TTD”) in the amount of $8,976.00; SEB in the amount of $28,443.43; penalties in the amount of $6,490.33; and attorney's fees in the amount of $10,000.00. The WCJ also ordered Ryder to pay Miranda's outstanding medical bill in the amount of $2,017.00 to LA Health.

Ryder appealed,³ arguing the WCJ erred in finding that Miranda: (1) was a credible witness; (2) carried his burden of proving an unwitnessed work accident while in the course and scope of his employment; (3) met his legal burden of proving injury related to the workplace accident; (4) is entitled to past due and future medical and indemnity benefits; and (5) is entitled to penalties and attorney's fees. Miranda filed an answer to the appeal in which he sought a modification of the WCJ's attorney's fees award and an award of costs of appeal.

STANDARD OF REVIEW

As in other civil cases, in reviewing the WCJ's factual determinations, including whether the claimant has discharged his burden of proof, this court is bound by the manifest error standard of review. Under that standard of review, an appellate court may only reverse a WCJ's factual determinations if it finds from the record that a reasonable factual basis for the finding does not exist and that examination of the entire record reveals that the finding is clearly wrong. Hirstius v. Tropicare Service, LLC, 2011-1080 (La. App. 1 Cir. 12/21/11), 80 So.3d 1215, 1216. Thus, the issue to be resolved by a reviewing court is not whether the trier of fact was right or wrong, but whether the factfinder's conclusion was a reasonable one. Mincey v. Rouse's Enterprises, LLC, 2023-0251 (La. App. 1 Cir. 11/3/23), 378 So.3d 126, 128. If the factfinder's findings are reasonable in light of the record reviewed in its entirety, the court of appeal may not reverse, even if convinced that had it been sitting as the trier of fact, it would have weighed the evidence differently. Mincey, 378 So.3d at 128.

BURDEN OF PROOF/CAUSATION

On appeal, Ryder contends the WCJ erred in finding Miranda and his witnesses to be credible and in finding their testimony was sufficient to carry Miranda's burden of proof that an accident occurred on the job site. In addition, Ryder claims that without proof of a workplace accident, Miranda has also failed to prove entitlement to medical or indemnity benefits.

The Louisiana Workers’ Compensation Act provides coverage to an employee for personal injury caused by an accident arising out of and in the course of his employment. La. R.S. 23:1031(A). An employee must prove the chain of causation required by the workers’ compensation statutory scheme, as adopted by the legislature, and must establish that the accident was employment-related, that the accident caused the injury, and that the injury caused the disability. Hirstius, 80 So.3d at 1216.

Initially, a workers’ compensation claimant has the burden of establishing by a preponderance of the evidence that an accident occurred on the job and that he sustained an injury. Alvis v. Peninsula Gaming Partners, LLC, 2020-0161 (La. App. 1 Cir. 11/12/20), 316 So.3d 54, 58. A worker's testimony alone may be sufficient to discharge the burden of proving that an accident occurred on the job and that the worker sustained an injury provided two elements are satisfied: (1) no other evidence discredits or casts serious doubt upon the worker's version of the incident; and (2) the worker's testimony is corroborated by the circumstances following the alleged incident. Rayborn v. Continental Cement Company, LLC, 2023-0403 (La. App. 1 Cir. 1/10/24), 383 So.3d 225, 233 (citing Bruno v. Harbert International Inc., 593 So.2d 357, 361 (La. 1992)), writ denied, 2024-00190 (La. 4/3/24), 382 So.3d 110. Corroboration of the worker's testimony may be provided by the testimony of co-workers, spouses, friends, or by medical evidence. Rayborn, 383 So.3d at 233.

Once an employee establishes that an accident occurred on the job, the employee must establish a causal connection between the accident and the resulting disability by a preponderance of the evidence. Alvis, 316 So.3d at 58. Causation is not necessarily and exclusively a medical conclusion. It is usually the ultimate fact to be found by the factfinder based on all credible evidence. Alvis, 316 So.3d at 58.

Although procedural rules are construed liberally in favor of workers’ compensation claimants, the burden of proof—a preponderance of the evidence—is not relaxed. Alvis, 316 So.3d at 58. Accordingly, the testimony as a whole must show that more probably than not an employment accident occurred and that it had a causal relation to the injury. If the testimony leaves the probabilities equally balanced, the plaintiff has failed to carry the burden of persuasion. Likewise, the plaintiff's case must fail if the evidence shows only a possibility of a causative accident or leaves it to speculation or conjecture. Alvis, 316 So.3d at 58.

At trial, Miranda testified that on the weekend before the accident, he and his wife took a trip to Mississippi to celebrate their wedding anniversary. Miranda testified that on his return to work on Monday, April 22, 2024, he injured himself while installing stickers on the 18-wheelers. Miranda stated he left work at the end of his shift shortly after the incident, and he did not return until May 1, 2024, “due to his ongoing symptoms.”

Miranda alleged that upon his return to work on May 1, 2024, he asked Shally if he could make an accident report and see a doctor. According to Miranda, Shally stated only that Miranda “should have reported it when [Caye] was there.”⁴ Approximately a week later, Miranda brought up his request to file an accident report and to see a doctor to Shally again. Miranda stated that Shally brought him an incident reporting form and the next day, he was sent to Pelican.

On a separate doctor's visit to LA Health on May 15, 2024, Miranda was diagnosed with several injuries to his neck and shoulder. Miranda then saw Dr. Johnson at LA Health on May 20, 2024, who noted the accident took place at work, listed Miranda's work status as “Temporarily Disabled,” and ordered an MRI. The MRI revealed a herniated C6-7 disc with an extruded fragment causing pressure primarily on the right side, and Dr. Johnson wrote Miranda a referral to neurosurgery.

Miranda met with an orthopedist, Dr. Bostick, on July 31, 2024. Dr. Bostick opined Miranda's injuries “are attributed to the accident which occurred on 4/22/24[,]” and he recommended sedentary work and “[n]o overhead reaching, no lifting, no push/pulling with right shoulder/arm.” Miranda has not been employed since he left Ryder.

Caye confirmed Miranda's version of events during his deposition. Caye explicitly stated that Miranda told him and Shally on April 22, 2024, that he hurt his shoulder at work that day and explained how it happened. Miranda's wife also testified that Miranda told her that he injured his shoulder at work on April 22, 2024. Both Caye and Miranda's wife testified Miranda never complained of shoulder pain before the accident.

Testimony elicited at trial by counsel for Ryder revealed slight inconsistencies in Miranda's version of events. For example, Miranda testified there were no witnesses to the incident, while Caye stated during his deposition that there were three witnesses. Caye also stated during his deposition that Miranda reported the accident to him in the morning, rather than after lunch as Miranda asserted. In addition, the testimony of Miranda and his wife revealed slightly different accounts of the accident and the nature of his injuries.

Shally explicitly denied that Miranda reported the accident to him and Caye on April 22, 2024. Shally stated that Miranda told him on April 22, 2024, that he was “hurt at home.” According to Shally, he, Miranda, and Caye were standing outside Caye's office on April 22, 2024, and Caye was “trying to convince [Miranda] to file a claim” but Miranda did not want to “because everybody already knew he had hurt it over the weekend at home and [he] didn't want to get in trouble.” According to Shally, the first day Miranda claimed he hurt himself at work was May 8, 2024, which also happened to be the first day Miranda asked to see a doctor.

Shally stated that he instructed one of Miranda's co-workers, Jordan Calhoun, to review and collect video footage from the day of the accident. Shally testified that he personally watched the surveillance videos with Calhoun and that there was no footage of Miranda putting any stickers on the trucks.

Calhoun also confirmed that Miranda told him he hurt his arm over the weekend prior to April 22, 2024, and he testified that Miranda said his shoulder was “still sore and ․ wasn't really hurting.” Calhoun testified that Miranda told him he “re-tweaked” his arm at work while installing stickers on the trucks. Calhoun testified that he reviewed all video footage from the time Miranda was on Ryder's premises on April 22, 2024, and none of the video footage showed Miranda falling or hurting himself.⁵

Ryder contends that the inconsistencies in Miranda's testimony and the testimony of his witnesses, when coupled with the testimony of Shally and Calhoun, render Miranda and his witnesses wholly unreliable. We disagree. Where, as here, the evidence supports two permissible views, a factfinder's choice of one of the views cannot be clearly wrong or manifestly erroneous, and reasonable evaluations of credibility and interferences of fact should not be disturbed upon review. See McGlothlin v. Christos St. Patrick Hosp., 2010-2775 (La. 7/1/11), 65 So.3d 1218, 1237; Bella v. Knieper, 2024-0277 (La. App. 1 Cir. 11/20/24), 405 So.3d 1039, 1045, writ denied, 2024-01563 (La. 4/8/25), 405 So.3d 575. In its reasons for judgment, the WCJ noted Miranda “presented as a credible witness” and “repeatedly provided the same history about the accident and his symptoms to his medical providers and his supervisors.” In addition, Miranda offered the testimony of Caye and his wife, both of whom confirmed Miranda told them he sustained injuries as a result of a workplace accident on April 22, 2024.

After thorough review of the evidence, we find a reasonable factual basis exists to support the WCJ's conclusion that Miranda carried his burden of proof to establish by a preponderance of the evidence that he suffered a workplace accident while working at Ryder. See Hirstius, 80 So.3d at 1216. Additionally, the medical records establish causation. For these reasons, we find no manifest error in the WCJ's finding.

PENALTIES, ATTORNEY'S FEES, AND COSTS

The claimant bears the burden of proving entitlement to statutory penalties and attorney's fees due to the employer's failure to timely pay workers’ compensation benefits. Bonvillian v. Great American Alliance Insurance Company, 2024-1025 (La. App. 1 Cir. 5/22/25), 417 So.3d 731, 735. Under La. R.S. 23:1201(F), an employer may be liable for penalties and attorney's fees for its failure to authorize indemnity benefits except when the claim is reasonably controverted. Nevertheless, penalties and attorney's fees are inappropriate if the claim is reasonably controverted or if such nonpayment results from conditions over which the employer or insurer had no control. La. R.S. 23:1201(F)(2). A claim is reasonably controverted when the employer has sufficient factual and/or medical information to counter evidence presented by the claimant. Lee v. Smitty's Supply, Inc., 2024-0460 (La. App. 1 Cir. 12/20/24), 404 So.3d 916, 927.

An award of penalties and attorney's fees under the Louisiana Workers’ Compensation Act are penal in nature and are imposed to deter indifference and undesirable conduct by employers and their insurers toward injured workers. Bonvillian, 417 So.3d at 737. Although the Workers’ Compensation Act is to be liberally construed regarding benefits, penal statutes are to be strictly construed. Bonvillian, 417 So.3d at 737. The crucial inquiry in proving entitlement to statutory penalties and attorney's fees is whether the employer has an articulated and objective reason for denying payment at the time it took that action. Bonvillian, 417 So.3d at 737. Penalties for nonpayment of benefits should not be imposed in doubtful cases, where a bona fide dispute exists as to the claimant's entitlement to benefits, and the mere fact that an employer loses a disputed claim is not determinative. Alvis, 316 So.3d at 60. A WCJ's decision to impose penalties is a factual finding subject to the manifest error standard of review, while a WCJ's award of penalties and attorney fees—i.e., the actual amount awarded—is entitled to great discretion and will not be disturbed absent an abuse of discretion. Millender v. BASF Corp., 2013-2253 (La. App. 1 Cir. 12/23/14), 168 So.3d 649, 658.

Ryder argues the WCJ was clearly wrong in awarding penalties, attorney's fees, and costs to Miranda. Ryder maintains Miranda's claim was reasonably controverted, as it was unwitnessed and unreported until weeks after the alleged incident. Immediately after the accident was officially reported on May 8, 2024, Miranda was sent to the doctor, and per the doctor's instructions, was provided with an accommodated position. Ryder also asserts that the lack of video evidence of a fall is further evidence of a reasonable basis to deny compensation.⁶

The WCJ assessed penalties in the amount of $2,000.00 for Ryder's failure to timely or otherwise authorize and/or pay for necessary and related medical care as a result of the April 22, 2024 accident. The WCJ assessed additional penalties in the amount of $4,490.33 for Ryder's failure to timely or otherwise pay indemnity benefits as a result of the April 22, 2024 accident. Lastly, the WCJ awarded attorney's fees to Miranda in the amount of $10,000.00 for those failures.

In assessing, these awards, the WCJ noted Miranda's attorney sent a demand letter to Ryder on May 16, 2024, along with a LA Health report that reflected Miranda presented with complaints of an injury that took place at work and declared him temporarily disabled. Nevertheless, Ryder's claims adjuster denied the claim, stating there was “no medical evidence that [the] alleged injury occurred at work.” In response, Miranda sent a notice of disagreement and included: (1) Dr. Johnson's May 20, 2024 report finding disability and relating that disability to the April 22, 2024 accident; and (2) Caye's affidavit, wherein he attested that Miranda reported to him that he was injured while working in his capacity as a technician for Ryder.

The WCJ found that “[a]t the time Mr. Miranda made that demand, [Ryder] had no evidence to contradict Mr. Miranda's need for medical care or whether the care was related.” The WCJ further noted that “[a]n adjuster who ignores the possibility that an accident caused the medical condition when there is evidence of causation[ ] has failed to fulfill his duty to investigate and to make every reasonable effort to assemble medical information to determine whether the accident caused the injury before denying those benefits.” See Perrilloux v. First Guar. Bank, 2009-0054 (La. App. 1 Cir. 10/9/09), 29 So.3d 511, 515. Despite having medical information relating to Miranda's injuries and disability status as a result of the April 22, 2024 work-related accident, Ryder did not pay Miranda any medical or indemnity benefits other than the payment it made when it initially sent Miranda to Pelican. Accordingly, we find a reasonable factual basis in the record for the WCJ's decision to impose penalties and attorney's fees under La. R.S. 23:1201(F).

MIRANDA'S ANSWER TO APPEAL

Miranda filed an answer to the appeal in which he seeks a modification of the WCJ's attorney's fees award to include: (1) an additional $5,000.00 for the work performed in prosecuting his claim and (2) additional attorney's fees incurred in opposing the appeal.

As previously stated, the amount of a WCJ's award of penalties and attorney fees will not be disturbed absent an abuse of discretion. Millender, 168 So.3d at 658. Factors to be considered in the imposition of reasonable attorney fees in workers’ compensation cases include the degree of skill and work involved in the case, the amount of the claim, the amount recovered, and the amount of time devoted to the case. Considering the factors stated above and the record before us, we do not find that WCJ abused its discretion in the amount awarded. Millender, 168 So.3d at 663.

Additional attorney's fees are usually awarded on appeal when a party appeals, but obtains no relief, and the appeal has necessitated additional work on the opposing party's counsel, provided that the opposing party appropriately requests an increase. Lee, 404 So.3d at 929. An appellate court has discretion to award or increase attorney fees for defending an appeal based on factors such as the attorney's skill and the amount of time and work reflected in the appeal. Gulf States Contractors, L.L.C. v. Davie Shoring, Inc., 2024-1315 (La. App. 1 Cir. 8/8/25), 418 So.3d 1106, 1118, writ denied, 2025-01136 (La. 11/19/25), 420 So.3d 1185. We elect to exercise this discretion. Therefore, we award $1,500.00 in additional attorney's fees for work done on appeal.

DECREE

For the above and foregoing reasons, the WCJ's June 23, 2025 judgment in favor of the employee, Lajoal Miranda, and against the employer/defendants, Ryder Services Corporation and Ryder Truck Rental, Inc., is affirmed. The employee's answer to the appeal is granted in part to award an additional $1,500.00 to Lajoal Miranda for attorney's fees for work done on appeal. The answer is denied in all other respects. Costs of this appeal are assessed to Defendants, Ryder Services Corporation and Ryder Truck Rental, Inc.

AFFIRMED; ANSWER TO APPEAL GRANTED IN PART AND DENIED IN PART.

FOOTNOTES

1.   Caye also happens to be Miranda's father-in-law.

2.   Ryder Truck Rental, Inc. is self-insured by Ryder Services Corporation. We refer to them collectively as “Ryder.”

3.   Notice of signing of judgment was mailed to the parties on June 26, 2025. Ryder filed a motion and order for devolutive appeal on August 14, 2025.

4.   Caye left his employment with Ryder prior to Miranda's return to work for reasons unrelated to the alleged accident.

5.   Calhoun admitted that he intentionally did not save the entire video footage available from that day. Instead, he only saved four videos that he deemed “significant.”

6.   We note, as the WCJ noted, that only partial video evidence was saved from Ryder's premises; therefore, we find no error in the WCJ's characterization of the video evidence as “unreliable at best.”

EDWARDS, J.