Providing False Medical History In a Work Related Injury Case

In Newcomer v. Workmen's Compensation Appeal Board (Ward Trucking Co.), 547 Pa. 639, 692 A.2d 1062 (1997), the claimant's expert opined that the claimant suffered from a work-related shoulder injury, basing this opinion solely on the false medical history provided by the claimant, without any personal review of the records relating to Claimant's original injury. In affirming the denial of the petition to reinstate benefits, our supreme court concluded that, although an expert witness may base an opinion on facts of which he has no personal knowledge, those facts must be supported by evidence of record and a medical opinion that is not supported by the record is not competent. Id.