Bakula v. WCAB (Budd Company)

Bakula v. Workmen's Compensation Appeal Board (Budd Company), 134 Pa. Commw. 37, 577 A.2d 961 (Pa. Cmwlth. 1990), provides that a claimant's testimony regarding his limitations is highly relevant to a determination of specific loss. In Bakula, this Court discussed both the medical evidence and the claimant's testimony concerning a loss of use of his finger, and remanded for further findings because the WCJ had made a mistake as to the contents of the doctor's report. In Bakula, the Court stated that the claimant's testimony regarding loss of use is relevant as "further support" for a finding of specific loss. Stated otherwise, competent medical evidence of permanent loss of use for all practical intents and purposes must be presented before "further support" in the form of a claimant's testimony can be considered.