United States Department of Labor

Employees’ Compensation Appeals Board

__________________________________________

J.L., Appellant

and

U.S. POSTAL SERVICE, DALTON POST 

OFFICE, Dalton, GA, Employer

__________________________________________

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Docket No. 23-0702

Issued: October 31, 2023

Appearances: Case Submitted on the Record

Appellant, pro se

Office of Solicitor, for the Director

DECISION AND ORDER

Before:

PATRICIA H. FITZGERALD, Deputy Chief Judge

VALERIE D. EVANS-HARRELL, Alternate Judge

JAMES D. McGINLEY, Alternate Judge

JURISDICTION

On April 19, 2023 appellant filed a timely appeal from a March 1, 2023 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 appellant has met his burden of proof to establish a left thumb 

condition causally related to the accepted factors of his federal employment. 

FACTUAL HISTORY

On January 23, 2023 appellant, then a 55-year-old carrier technician, filed an occupational 

disease claim (Form CA-2) alleging that in August 2022 he developed a left thumb condition due 

to factors of his federal employment, which included casing mail and gripping the steering wheel 

1

5 U.S.C. § 8101 et seq.
2

throughout the course of his workday. He noted that he first became aware of his condition and 

realized its relation to his federal employment on August 15, 2022. Appellant did not stop work.

In a November 28, 2022 report, Dr. Sierra G. Phillips, a Board-certified orthopedic 

surgeon, reported that appellant presented for evaluation of left thumb pain localized at the base 

which had been ongoing for three to four months. She noted that appellant worked as a mailman 

and believed that his pain was related to jamming his thumb in his steering wheel, as well as 

carrying heavy objects and opening mailboxes in his employment duties. Appellant reported that 

his pain improved when he was notworking and would worsen after overuse from his employment 

duties at the end of the workday. Dr. Phillips noted a prior right thumb carpometacarpal (CMC) 

joint arthroplasty performed by a different surgeon one year prior. She reviewed April 19, 2022 

diagnostic studies of the hands, which demonstrated right-hand posttrapeziectomy changes and 

scaphotrapeziotrapezoidal degenerative changes. Dr. Phillips noted that the left hand revealed 

moderate thumb CMC degenerative changes. She diagnosed left thumb CMC arthritis.

Dr. Phillips noted the natural history of arthritis and the natural progressive nature with intermittent 

flareups. She opined that appellant’s recent bout of pain was related to the steering wheel injury 

from work, which had been exacerbated by the repetitive activitiesrequired by his job. Dr. Phillips 

suggested conservative treatment and provided an intra-articular steroid injection at the site of 

injury.

In a January 9, 2023 report, Dr. Phillips noted his evaluation of appellant and noted 

improvement following the last intra-articular injection administered into the left thumb. She 

related that appellant wore a brace with difficulty when there was an increasing workload.

Dr. Phillips recommended continued conservative treatment. In an attending physician’s report 

(Form CA-20) of even date, Dr. Phillips diagnosed left thumb CMC arthritis. She checked a box 

marked “Yes” indicatingthat the diagnosed condition was caused or aggravated by an employment 

activity.

In a January 22, 2023 narrative statement, appellant described the employment duties he 

attributed to the cause of his left thumb injury. He reported that he began to experience left thumb 

pain on or around August 15, 2022, when he was driving his postal truck and caught his thumb in 

the steering wheel as he was making a turn onto another street. The pain continued to worsen over 

the next few months, causing him to seek treatment with an orthopedic physician. Appellant

further described his regular employment duties throughout his workday, which exacerbated his 

left thumb condition by pushing down the thumb joint, resulting in pain. These tasks included 

holding stacks of flats in his left hand as he cased mail, thumbing through mail with his left hand 

for deliveries, casing mail for one to two hours each day, gripping the steering wheel and steering 

throughout the day, and driving the postal truck to deliver mail for six to eight hours per day, which 

caused increasing pain in his left thumb. He explained that any other use of his left hand for 

gripping caused pain in his thumb joint. Appellant reported no previous left thumb condition prior 

to this injury.

In a January 27, 2023 development letter, OWCP informed appellant of the deficiencies of 

his claim. It advised him as to the type of factual and medical evidence required and provided a 

questionnaire for his completion. In a separate development letter of even date, OWCP requested 

that the employing establishment provide additional information pertaining to appellant’s 

occupational disease claim. It afforded both parties 30 days to respond. 
3

Following OWCP’s development letter, appellant resubmitted Dr. Phillips’ January 9, 

2023 medical report.

By decision dated March 1, 2023, OWCP denied appellant’s occupational disease claim, 

finding that the medical evidence of record was insufficient to establish causal relationship 

between his diagnosed left thumb condition and the accepted factors of his federal employment. 

LEGAL PRECEDENT

An employee seeking benefits under FECA2 has the burden of proof to establish the 

essential elements of his or her claim, including that the individual is an employee of the United 

States within the meaning of FECA, that the claim was timely filed within the applicable time 

limitation of FECA,3that an injury was sustained in the performance of duty as alleged, and that 

any disability or medical condition for which compensation is claimed is causally related to the 

employment injury.4 These are the essential elements of each and every compensation claim, 

regardless of whether the claim is predicated upon a traumatic injury or an occupational disease.5

To establish that an injury was sustained in the performance of duty in an occupational 

disease claim, an employee must submit the following: (1) a factual statement identifying 

employment factors alleged to have caused or contributed to the presence or occurrence of the 

disease or condition; (2) medical evidence establishing the presence or existence of the disease or 

condition for which compensation is claimed; and (3) medical evidence establishing that the 

diagnosed condition is causally related to the employment factors identified by the employee. 6

Causal relationship is a medical question that requires rationalized medical opinion 

evidence to resolve the issue.7 A physician’s opinion on whether there is causal relationship 

between the diagnosed condition and the implicated employment factor(s) must be based on a 

complete factual and medical background.8 Additionally, the physician’s opinion must be 

expressed in terms of a reasonable degree of medical certainty, and must be supported by medical 

2

Id.

3 E.K., Docket No. 22-1130 (issued December 30, 2022); F.H., Docket No. 18-0869 (issued January 29, 2020);

J.P., Docket No. 19-0129 (issued April 26, 2019); Joe D. Cameron, 41 ECAB 153 (1989).

4

S.H., Docket No. 22-0391 (issued June 29, 2022); L.C.,Docket No. 19-1301 (issued January 29, 2020);

J.H., Docket No. 18-1637 (issued January 29, 2020); James E. Chadden, Sr., 40 ECAB 312 (1988). 

5 E.H., Docket No. 22-0401 (issued June 29, 2022); P.A., Docket No. 18-0559 (issued January 29, 2020);

K.M., Docket No. 15-1660 (issued September 16, 2016); Delores C. Ellyett, 41 ECAB 992 (1990). 

6 R.G., Docket No. 19-0233 (issued July 16, 2019);see also RoyL. Humphrey, 57 ECAB 238, 241 (2005);Ruby I. 

Fish, 46 ECAB 276, 279 (1994); Victor J. Woodhams, 41 ECAB 345 (1989).

7

S.M., Docket No. 22-0075 (issued May 6, 2022); S.S., Docket No. 19-0688 (issued January 24, 2020);

A.M., Docket No. 18-1748 (issued April 24, 2019); Robert G. Morris, 48 ECAB 238 (1996).

8 M.V., Docket No. 18-0884 (issued December 28, 2018).
4

rationale explaining the nature of the relationship between the diagnosed condition and appellant’s 

specific employment factor(s).9

ANALYSIS

The Board finds that appellant has not met his burden of proof to establish a left thumb 

condition causally related to the accepted factors of his federal employment.

10

In support of his claim, appellant submitted reports dated November 28, 2022 and 

January 9, 2023, wherein Dr. Phillips noted that appellant complained of continued left thumb pain 

at the base following a work-related incident when he caught his thumb in the steering wheel of 

his postal vehicle. Dr. Phillips described appellant’s employment duties, which she attributed to

his injury. She opined that appellant’s recent bout of pain was related to the work-related steering 

wheel injury, which had been exacerbated by his repetitive employment duties. However,

Dr. Phillips’ statement that appellant’s employment duties caused his claimed left thumb condition 

is vague and generalized in the absence of medical rationale explaining how the specific 

movements caused or contributed to the diagnosed condition.11 The Board has held that without 

explaining how appellant’s employment duties caused or aggravated his condition, an opinion on 

causal relationship is of limited probative value.12 Thus, these reports are insufficient to meet 

appellant’s burden of proof. 

The January 9, 2023 Form CA-20 is also insufficient to establish appellant’s claim. In a

Form CA-20 dated January 9, 2023, Dr. Phillips diagnosed left thumb CMC arthritis and checked 

a box marked “Yes” indicating that the diagnosed condition was caused or aggravated by the 

reported employment activity. However, she provided no rationale for her opinion on causal 

relationship. The Board has held that when a physician’s opinion on causal relationship consists 

only of checking “Yes” to a form question, without more by the way of medical rationale, that 

opinion is of limited probative value and is insufficient to establish causal relationship. 13 As such, 

this report is insufficient to establish the claim.

As the medical evidence of record is insufficient to establish causal relationship between 

appellant’s diagnosed left thumb condition and the accepted factors of his federal employment, the 

Board finds that he has not met his burden of proof.14

9

J.D., Docket No. 22-0935 (issued December 16, 2022); T.L.,Docket No. 18-0778 (issued January 22, 2020);

Y.S., Docket No. 18-0366 (issued January 22, 2020); Victor J. Woodhams, 41 ECAB 345, 352 (1989).

10 C.J., Docket No. 22-1015 (issued March 31, 2023); J.D., Docket No. 21-0470 (issued December 2, 2022).

11 R.T., Docket No. 18-0581 (issued October 3, 2018).

12 See A.P., Docket No. 19-0224 (issued July 11, 2019).

13 S.T., Docket No. 22-1025 (issued January 3, 2023).

14 I.D., Docket No. 22-0848 (issued September 2, 2022); T.G., Docket No. 14-751 (issued October 20, 2014).
5

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 appellant has not met his burden of proof to establish a left thumb 

condition causally related to the accepted factors of his federal employment. 

ORDER

IT IS HEREBY ORDERED THAT the March 1, 2023 decision of the Office of Workers’

Compensation Programs is affirmed.

Issued: October 31, 2023

Washington, DC

Patricia H. Fitzgerald, Deputy Chief Judge

Employees’ Compensation Appeals Board

Valerie D. Evans-Harrell, Alternate Judge

Employees’ Compensation Appeals Board

James D. McGinley, Alternate Judge

Employees’ Compensation Appeals Board