Complex Regional Pain Syndrome: Connecting Scheduled and Unscheduled Injuries in Wisconsin Workers Compensation.

Since 1993, Complex Regional Pain Syndrome (CRPS) has become the term used by health professionals to describe the condition formerly known as Reflex Sympathetic Dystrophy now CRPS-I, and Causalgia now CRPS-II. Both CRPS types I and II are characterized with excessive or prolonged pain, changes in skin temperature and color or appearance, and swelling. The treatment for CRPS-I and CRPS-II are very similar. The main difference between Type I and Type II is that Type II will have confirmed nerve injury, unlike Type I which is very difficult to detect.[1],[2] The majority of CRPS claims in worker’s compensation will fall under the CRPS-I diagnosis which is difficult to diagnose.

What Causes CRPS-I?

In over 90% of cases, CRPS-I is caused injuries or trauma such as bone fractures, soft tissue injuries, surgery, limb immobilization, and other medical procedures. Medical researchers are not certain why some people with those types of injuries develop CRPS-I and others do not. CRPS-I patients’ generally have abnormalities of the peripheral nerves, which transmit signals from the brain to the rest of the body. The peripheral nerves also send signals to the blood vessels and immune system, which can cause the physical responses that change the limbs temperature or color.[3]

How Does CRPS-I Affect Your Worker’s Compensation Claim?

The diagnosis of CRPS-I arising out of a work related scheduled injury, such as a hand or foot injury, can cause symptoms and pain to spread throughout the body. For example, a worker injures his right knee from slipping and falling on the ice in the parking lot on the way to work. The worker needs surgery for the knee, while recovering the worker develops an abnormal gate and CRPS-I. The worker’s abnormal gate and CRPS-1 has caused pain to spread into his lower back and left leg.

The Labor and Industry Review Commission (LIRC) has had several different decisions that are applicable for this worker. In Michael S. Murawski v. Contract Transport Services, WC Claim No. 2000-041229 (LIRC Nov. 26, 2003), LIRC determined from the testimony and the medical records there was not any permanent disability from the CRPS-I or to an unscheduled part of the body. This decision has brought about a lot of concern that CRPS-I cases would not be considered unscheduled injuries and eligible for loss of earning capacity and permanent total disability claims.

Is that all that can be done? No, LIRC has established that persuasive medical opinions and medical records that credibly connect the original scheduled work injury had spread and caused the worker’s permanent total disability to an unscheduled body part.[4] While not specifically a CRPS-I case, LIRC recently supported the connection of a work related scheduled injury to a foot had caused the unscheduled injury to the worker’s back.[5] These cases whether a loss like Murawski or a win like Tomasovich continue to build the case law that will connect conditions like CRPS-I that spread through both scheduled and unscheduled injuries. This provides injured workers the ability to receive loss of earning capacity and permanent total disability for injuries that began as a scheduled injury.

What should you take away?

First, if you have been diagnosed with CRPS-I after sustaining a work related injury, then your doctor’s support and medical records are going to be very important.

Second, if you do experience difficulties with your worker’s compensation claim because of that diagnosis in the form of a denial or dispute from an independent medical examination, then you will need legal representation.

Third, if you are looking for legal representation for your CRPS-I, CRPS-II, or secondary injury cases you will need a worker’s compensation attorney that understands and has experience with these types of cases, then you should consult Tabak Law at 414-351-4400.

Attorney Hannah R. Zacharias

[1] The information for the section was provided by the National Institute of Neurological Disorders and Stroke, Complex Regional Pain Syndrome Fact Sheet (April 2, 2019, 4:11 PM),

[2] Giovanni Iolascon, et al., Complex Regional Pain Syndrome (CRPS) Type I: Historical Perspective and Critical Issues, Clinical Cases in Mineral and Bone Metabolism (April 2, 2019, 4:15 PM),

[3] Complex Regional Pain Syndrome Fact Sheet (April 2, 2019, 4:11 PM),

[4] Veronica L McNaughton v. Wal-Mart Associates Inc. WC Claim No. 2005-014491 (LIRC July 23, 2012) discussing Tomasovich v. County Transit Corp., WC Claim No. 1995-055411 (LIRC June 6, 2003).

[5] Marty Mendez v. Mayville Engineering Co., Inc., WC Claim No. 2014-023612 (LIRC Nov. 20, 2018).

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