United States Department of Labor 

Employees’ Compensation Appeals Board 

__________________________________________ 

J.T., Appellant 

and 

U.S. POSTAL SERVICE, PARKLAWN 

STATION, Milwaukee, WI, Employer 

__________________________________________ 

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Docket No. 15-196 

Issued: March 23, 2015 

Appearances: Case Submitted on the Record

Appellant, pro se 

Office of Solicitor, for the Director 

DECISION AND ORDER 

Before: 

CHRISTOPHER J. GODFREY, Chief Judge 

COLLEEN DUFFY KIKO, Judge 

PATRICIA HOWARD FITZGERALD, Judge 

JURISDICTION 

On November 5, 2014 appellant filed a timely appeal from a September 19, 2014 merit 

decision of the Office of Workers’ Compensation Programs (OWCP). Pursuant to the Federal 

Employees’ Compensation Act1

 (FECA) and 20 C.F.R. §§ 501.2(c) and 501.3, the Board has 

jurisdiction over the merits of this case. 

ISSUE 

The issue is whether carrying a mailbag aggravated appellant’s right hip osteoarthritis on 

January 15, 2014, as alleged. 

FACTUAL HISTORY 

On January 17, 2014 appellant, a 43-year-old city carrier, filed a traumatic injury claim 

alleging that he sustained a hip injury in the performance of duty on January 15, 2014. He stated 

on the claim form, “Just walking with mailbag and hip went out on me.” 

 1

 5 U.S.C. § 8101 et seq.
2

Dr. Daniel J. Thompson, Board-certified in internal medicine, related appellant’s history 

of present illness and noted that x-rays demonstrated severe degenerative arthritis of the right hip 

with near total loss of the joint space in the superior portion of the joint. He noted that these 

findings were consistent with the type of pain appellant was having. Dr. Thompson completed 

an attending physician’s form report. With an affirmative mark, he indicated that appellant’s 

condition was aggravated by carrying a mailbag at work. 

OWCP denied appellant’s claim on March 10, 2014. It found that the work activity 

occurred as alleged but that the medical evidence did not provide a well-reasoned explanation of 

how the work activity caused the diagnosed osteoarthritis. OWCP noted that osteoarthritis 

develops over time due to many factors, including the natural progression of age. 

Dr. Thompson completed another attending physician’s form report. He indicated again 

that appellant’s right hip condition was aggravated by walking the distance appellant walked 

with the weight that he carried. 

Appellant requested reconsideration of OWCP’s March 10, 2014 decision. 

Dr. Ankur N. Patel, Board-certified in internal medicine, noted that appellant was 

suffering from severe pain in the right hip due to carrying a heavy bag of mail. He had severe 

degenerative joint disease of the right hip joint and now had a problem with walking and 

balance. Until surgery was performed, Dr. Patel found that appellant should be on light duty. 

In a decision dated September 19, 2014, OWCP reviewed the merits of appellant’s claim 

and denied modification of its prior decision. It found that the medical evidence did not present 

a rationalized statement supported by findings on examination and objective test results 

explaining how the diagnosed condition of severe osteoarthritis was the result of the incident on 

January 15, 2014.2

LEGAL PRECEDENT 

FECA provides compensation for the disability of an employee resulting from personal 

injury sustained while in the performance of duty.3

 An employee seeking benefits under FECA 

has the burden of proof to establish the essential elements of his or her claim. When an 

employee claims that he or she sustained an injury in the performance of duty, he or she must 

submit sufficient evidence to establish that he or she experienced a specific event, incident or 

exposure occurring at the time, place, and in the manner alleged. He or she must also establish 

that such event, incident or exposure caused an injury.4

 2

 On April 16, 2014 appellant filed an occupational disease claim alleging that his right hip condition was the 

result of walking and carrying mail. As OWCP has not issued a final decision on this claim it is not before the 

Board on this appeal. See 20 C.F.R. § 501.2(c). 

3

 5 U.S.C. § 8102(a). 

4 John J. Carlone, 41 ECAB 354 (1989). 
3

Causal relationship is a medical issue,5 and the medical evidence generally required to 

establish causal relationship is rationalized medical opinion evidence. The opinion of the 

physician must be based on a complete factual and medical background of the claimant,6

 must be 

one of reasonable medical certainty,7

 and must be supported by medical rationale explaining the 

nature of the relationship between the diagnosed condition and the established incident or factor 

of employment.8

ANALYSIS 

OWCP accepts that appellant carried a mailbag in the course of his employment as a city 

carrier. Appellant has thus met his burden of proof to establish a specific event, incident or 

exposure occurring at the time, place, and in the manner alleged. The question is whether this 

employment activity aggravated the severe osteoarthritis found in his right hip. 

The medical opinion evidence is supportive of appellant’s claim, yet the evidence is not 

sufficient for appellant to have met his burden of proof. Dr. Thompson, the attending internist, 

completed two form reports indicating with an affirmative mark that appellant’s right hip 

condition was aggravated by carrying a mailbag over some distance at work. The Board has 

held, however, that when a physician’s opinion on causal relationship consists only of checking 

“yes” to a form question, that opinion has little probative value and is insufficient to establish 

causal relationship.9 Appellant’s burden includes the necessity of furnishing an affirmative 

opinion from a physician who supports his conclusion with sound medical reasoning. As 

Dr. Thompson did no more than check “yes” to a form question, his opinion on causal relationship 

is of little probative value and insufficient to discharge appellant’s burden of proof. 

Dr. Patel, another internist, noted that appellant had severe degenerative joint disease of 

the right hip joint and was suffering from severe pain due to carrying a heavy bag of mail. 

Although this is also supportive of appellant’s claim, Dr. Patel offered no more medical rationale 

than Dr. Thompson did in his form reports. The mere fact that a condition manifests itself or 

worsens during a period of federal employment raises no inference of causal relationship between 

the two.10 There must be a medically sound and rational basis for finding a work-related 

aggravation of the condition. Otherwise, opinions supporting causal relationship must be regarded 

as speculative. 

As Dr. Thompson and Dr. Patel did not offer sound medical reasoning to support their 

opinions that carrying a heavy mailbag aggravated appellant’s right hip osteoarthritis, the Board 

 5 Mary J. Briggs, 37 ECAB 578 (1986). 

6 William Nimitz, Jr., 30 ECAB 567, 570 (1979). 

7 Morris Scanlon, 11 ECAB 384, 385 (1960). 

8 William E. Enright, 31 ECAB 426, 430 (1980). 

9 E.g., Lillian M. Jones, 34 ECAB 379 (1982). 

10 Steven R. Piper, 39 ECAB 312 (1987). 
4

finds that appellant has not met his burden to establish the critical element of causal relationship. 

The Board will, therefore, affirm OWCP’s September 19, 2014 decision. 

Appellant may submit new evidence or argument with a written request for 

reconsideration to OWCP within one year of this merit decision, pursuant to 5 U.S.C. § 8128(a) 

and 20 C.F.R. §§ 10.605 through 10.607. 

CONCLUSION 

The Board finds that the medical opinion evidence lacks sufficient rationale to establish 

that carrying a mailbag aggravated appellant’s right hip osteoarthritis on January 15, 2014, as 

alleged. 

ORDER 

IT IS HEREBY ORDERED THAT the September 19, 2014 decision of the Office of 

Workers’ Compensation Programs is affirmed. 

Issued: March 23, 2015 

Washington, DC 

 

 Christopher J. Godfrey, Chief Judge 

 Employees’ Compensation Appeals Board 

 

 Colleen Duffy Kiko, Judge 

 Employees’ Compensation Appeals Board 

 

 Patricia Howard Fitzgerald, Judge 

 Employees’ Compensation Appeals Board