Bullion Hollow Enters., Inc. v. Lane
In Bullion Hollow Enters., Inc. v. Lane, 14 Va. App. 725, 729, 418 S.E.2d 904, 907 (1992), the Court held that the Workers' Compensation Commission may disregard a deputy commissioner's express credibility determination when it "articulates its reasons" for doing so. 14 Va. App. at 729, 418 S.E.2d at 907.
Thus, "when a deputy commissioner makes an explicit finding of credibility based upon a witness' demeanor or appearance at the hearing, the commission may reverse that factual finding when it articulates a basis for its different conclusion that is supported by credible evidence." Id.
Conversely, absent an express credibility determination by the deputy commissioner, "the commission has no duty to explain its reasons." Id. at 729, 418 S.E.2d at 906.