Full Opinion

This opinion is subject to revision before final publication in the Pacific Reporter 2026 UT 29 IN THE SUPREME COURT OF THE STATE OF UTAH GRANITE SCHOOL DISTRICT, Petitioner, v. ROBYN YOUNG and UTAH LABOR COMMISSION, Respondents. No. 20240646 Heard October 15, 2025 Filed August 13, 2026* On Certification from the Court of Appeals Utah Labor Commission No. 18-0735 Attorneys: Bret A. Gardner, Kristy L. Bertelsen, Salt Lake City, for petitioner Gary E. Atkin, Salt Lake City, for respondent Robyn Young Christopher Hill, Salt Lake City, for respondent Utah Labor Commission JUSTICE NIELSEN authored the opinion of the Court, in which JUSTICE PETERSEN, ASSOCIATE CHIEF JUSTICE POHLMAN, JUDGE CHRISTIANSEN FORSTER, and JUDGE HANSEN joined. Due to his retirement, JUSTICE PEARCE did not participate herein; DISTRICT COURT JUDGE MATTHEW J. HANSEN sat. __________________________________________________________ * As of January 31, 2026, “The Supreme Court consists of seven justices.” UTAH CODE § 78A-3-101(1). Pursuant to Utah Supreme Court Standing Order No. 18, this court sat and rendered judgment in this matter as a division of five justices. GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court Before this case was decided, CHIEF JUSTICE DURRANT recused himself from this case and JUSTICE HAGEN stepped down from the court. JUSTICE NIELSEN and COURT OF APPEALS JUDGE MICHELE M. CHRISTIANSEN FORSTER, having reviewed the briefs and listened to a recording of the oral argument, substituted for CHIEF JUSTICE DURRANT and JUSTICE HAGEN and participated fully in this decision. JUSTICE JORGENSEN and JUSTICE DENT became members of the Court after oral argument in this matter and did not participate. JUSTICE NIELSEN, opinion of the Court: INTRODUCTION ¶1 While working as a special education teacher for Granite School District, Robyn Young suffered two head injuries at work that left her with debilitating migraines, difficulty sleeping, depression, and other limitations. Young’s first treating physician approved Young for light-duty employment, but Granite would not accommodate her work restrictions and fired her. In her first workers’ compensation claim, Young was awarded temporary total disability benefits, and Granite was ordered to pay her related medical expenses. But Granite disputed its liability and refused to pay some of those expenses. When the bills went unpaid, the hospital sent them to debt collection agencies. Those collection agencies began hounding Young for payment, causing her significant stress. Young eventually sued the collection agencies in federal court and received a cash settlement. Amidst all this, Young also got divorced. ¶2 After her condition failed to improve to the point that she could return to full-time work, Young filed a second workers’ compensation benefits claim, this time seeking an award of permanent total disability benefits. The administrative law judge (ALJ) held an evidentiary hearing and appointed a medical panel to evaluate the effects of the two industrial accidents apart from other stressors in her life (like the bill collectors and her divorce). The panel concluded that all of Young’s restrictions were related to her industrial accidents and that the additional stressors were passing and did not contribute to her permanent restrictions. ¶3 Granite twice attempted to reopen the evidentiary record to adduce evidence about two stressors that it believed actually caused her limitations: the collection agencies’ actions and Young’s 2 Cite as: 2026 UT 29 Opinion of the Court involvement—after the hearing—in a car accident in which a motorcyclist was killed. Granite also asserted a subrogation claim under Utah Code section 34A-2-106, arguing that it should receive a portion of Young’s federal lawsuit settlement because, in its view, those proceeds compensated her for her underlying injuries. ¶4 The ALJ denied Granite’s subrogation claim, refused to reopen the evidentiary record, credited the panel’s report, and ordered Granite to pay past medical expenses, future medical expenses, and permanent total disability benefits. Granite sought review with the Utah Labor Commission. The Commission rejected Granite’s arguments, agreeing with the ALJ. ¶5 Granite seeks judicial review of the Labor Commission’s order. First, Granite argues that the Commission failed to instruct the medical panel to determine whether Young’s limitations were a result of the work accidents as opposed to non-industrial stressors. But that is precisely what the medical panel was instructed to do and precisely what it did. ¶6 Second, Granite argues that the Labor Commission erred in declining to reopen the evidentiary record so that it could present evidence of both the debt collection actions and the post- hearing car accident. But whether to reopen the evidentiary record was a discretionary call, and there was no abuse of discretion where a medical panel determined that the debt collection efforts did not contribute to Young’s condition long-term and the car accident happened well after Young suffered permanent disability from the work accidents. ¶7 Third, Granite argues that the Labor Commission erred in awarding Young permanent total disability benefits, challenging the Commission’s findings on five of the six elements of Young’s permanent total disability claim. We conclude that there was substantial evidence in the record to support the Commission’s findings, so its permanent total disability award stands. ¶8 Finally, Granite argues that the Labor Commission erred in refusing to grant a subrogation offset under Utah Code section 34A-2-106. But on this record, it is clear that the federal lawsuit settlement compensated Young for the stress of the improper debt collection tactics, not for her underlying work injuries. ¶9 We decline to disturb the Commission’s order. 3 GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court BACKGROUND1 A. Young Suffers Two Head Injuries at Work that Cause Her Persistent Migraine Headaches and Depression ¶10 Robyn Young worked as a special education resource teacher for Granite School District. Young’s job required her to work full time and interact with students with disabilities. On two different occasions, she was injured by a student. ¶11 The first incident happened in 2013. Young was sitting behind a sixth-grade student when the “student threw his head back and ‘head butted’ [Young] in the face” three times. After this incident, Young was diagnosed with a concussion, received treatment, and returned to work after about one month. The second incident happened slightly over a year later in 2014, when a third- grade student punched Young in the left cheek with a closed fist, grabbed her by the hair, jerked her head around, and ripped chunks of her hair from her scalp. Young later explained that she felt as if she had been “beaten up” during this incident. ¶12 A few days after this second incident, Young went to an occupational medicine clinic, where she reported headaches, nausea, fatigue, and light sensitivity. She was diagnosed with a closed-head injury. She was released to return to work about a month later, but in the ensuing months she continued to have chronic headaches and went to the emergency room twice. She was diagnosed with post-concussive headaches and depression and referred to her first treating physician. ¶13 In July 2014, the first treating physician diagnosed Young with severe complications from recurrent migraines that “snowballed” from her cumulative head trauma and stemmed from the two work incidents. He further noted that Young had facial droop, ear pain, light sensitivity, foot dyskinesias (involuntary, erratic movements), and limb weakness due to her migraines. He concluded that Young was not medically stable and required further treatment. ¶14 A short time later, Young was interviewed by the first of three physicians acting as medical examiners for Granite. Granite’s __________________________________________________________ 1 “In reviewing a workers’ compensation order from the [Labor Commission], we view the facts in the light most favorable to the Commission’s findings and recite them accordingly.” Gamez v. Utah Lab. Comm’n, 2022 UT 20, n.3, 511 P.3d 1145 (cleaned up). 4 Cite as: 2026 UT 29 Opinion of the Court first physician opined that Young sustained a closed-head injury from the second incident. He agreed with her first treating physician that Young was not medically stable. ¶15 In February 2015, Young’s first treating physician released her “to light duty employment consisting of six to ten hours per week, no more than two hours per day.” He further directed that the classroom environment needed to provide low light and low noise to mitigate Young’s migraines. One morning during her first week of light-duty employment, Young woke up with a migraine, a drooping face, and paralysis in her hands and feet. Three days after she had been cleared to return to work, Granite informed Young that it would not accommodate her light-duty restrictions and terminated her employment. ¶16 Five months after that, Granite’s second physician evaluated Young. Granite’s second physician opined that Young sustained only a mild head and facial injury from the accident, that she reached medical stability in 2014, and that her ongoing symptoms were not a result of the work accident. Granite’s third physician agreed with the second physician’s opinions and added that preexisting psychological factors played an overriding role in Young’s ongoing physical and cognitive complaints. B. Young Files Her First Workers’ Compensation Benefits Claim and Is Awarded Temporary Total Benefits ¶17 In February 2015, Young applied for a hearing with the Labor Commission. Based on the 2013 and 2014 work accidents, Young sought medical expenses, medical care, temporary total disability compensation, and temporary partial disability compensation. The ALJ held an evidentiary hearing and referred the medical issues to a medical panel. The medical panel issued a report, opining that the “2013 industrial accident caused or worsened [Young’s] medical and psychological conditions,” and the “2014 industrial accident caused a second mild traumatic brain injury concussion, post concussive syndrome and an aggravation of a pre-existing anxiety and depression.” The ALJ adopted the medical panel’s report, awarded both temporary total disability compensation and temporary partial disability compensation, and ordered Granite to pay for all of Young’s medical expenses related 5 GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court to both industrial accidents.2 The Labor Commission Appeals Board affirmed the ALJ’s award. C. Young Files a Federal Fair Debt Collection Practices Act Lawsuit and Reaches a Monetary Settlement with Collection Agencies over Their Collection Efforts ¶18 Granite disputed its liability for various medical bills and refused to pay for certain treatment even though the ALJ determined that the condition being treated was caused by the industrial accidents. After the bills went unpaid, the hospital referred them to collection agencies, which began hounding Young through numerous calls and letters. These collection efforts eventually became “a considerable source of stress” for Young. ¶19 In 2016, Young filed a federal lawsuit against the collection agencies under the Fair Debt Collection Practices Act (FDCPA). The case ultimately settled in 2019. Under the settlement agreement, Young was compensated $610,000, of which she received $295,000. ¶20 Granite then sued Young in state district court, seeking reimbursement under the Utah Workers’ Compensation Act. See Granite Sch. Dist. v. Young, 2023 UT 21, ¶ 11, 537 P.3d 225. Granite alleged that it was entitled to reimbursement out of Young’s settlement proceeds because the injuries caused by the collection agencies were the same injuries for which Young had received workers compensation benefits from Granite. Id. Young moved to dismiss the case for lack of subject matter jurisdiction, and the district court dismissed the case. Id. ¶¶ 12–14. Granite appealed that dismissal to this court. Id. ¶ 14. We affirmed, explaining that “the district court . . . correctly determined that it lacked jurisdiction to decide the factual questions at the heart of this reimbursement dispute because our precedent dictates that the Labor Commission has exclusive jurisdiction over those questions.” Id. ¶ 4. __________________________________________________________ 2 “Industrial accident” is a term of art used throughout Utah’s Labor Code and denotes a workplace injury. See, e.g., UTAH CODE § 34A-2-401(1) (providing that compensation for industrial accidents shall be paid to employee’s “who [are] injured . . . by accident arising out of and in the course of the employee’s employment”). 6 Cite as: 2026 UT 29 Opinion of the Court D. Medical Experts Disagree on the Cause of Young’s Symptoms ¶21 After her first workers’ compensation claim concluded, Young continued to receive medical treatment from her first treating physician. In 2018, Young transferred her primary care to a new doctor. Young’s second treating physician performed neuropsychological and cognitive testing on Young and completed “a treating source statement of mental limitations regarding Ms. Young’s capacity.” The second treating physician’s report showed that she had several “moderate functional limitations” in her ability to do the sort of things that her teaching required, like seeing and correcting mistakes, reasoning through decisions, keeping up a consistent routine, following instructions, working with others, responding to feedback, and understanding when her work was acceptable (or not). He also opined that “Young would be absent from work more than four days per month and would potentially be off task 15–20% of the time.” ¶22 In 2019, Granite hired an additional medical examiner— this time, a psychologist—to evaluate Young. Granite’s psychologist attributed Young’s condition to preexisting factors, explaining that Young’s “chronic persistent physical symptoms over time are directly correlated to her emotional and psychiatric difficulties, unrelated to organic impairment and unrelated to her injuries sustained in 2013 and 2014.” ¶23 Young also hired a psychologist to assess the effects of the debt collectors’ actions on her condition. Young’s psychologist interviewed Young, several of her family members, and her therapist, and he reviewed several documents, including some depositions from Young’s federal lawsuit. Young’s psychologist opined that the debt collectors’ actions exacerbated Young’s migraines, neurologic symptoms, emotional distress, and psychological trauma. E. Young Files a Second Workers’ Compensation Claim, This Time Seeking Permanent Total Disability Benefits ¶24 In November 2018, Young applied again for a hearing with the Labor Commission. This time around, Young sought medical expenses, medical care, permanent total disability, unpaid interest, and reimbursement for out-of-pocket medical expenses that Granite had previously been ordered, but failed, to pay. Granite answered that Young’s claims failed for lack of medical and legal 7 GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court causation and that Young could not prove the elements of her permanent total disability claim. ¶25 The ALJ scheduled an evidentiary hearing in August 2019. A month before the hearing, Granite moved to compel discovery and continue the hearing. The ALJ denied Granite’s motions and ordered the record to “remain open” for a short time “to permit Granite School District to file its expert medical opinion.” ¶26 A couple of months later, Granite sent a letter to the ALJ stating that it sought “to introduce 4–5 deposition transcripts” that had been created as part of Young’s federal FDCPA case. Granite argued that the depositions should be admitted because they were the basis for the medical opinion of Young’s psychologist. Young objected on several grounds, including that admission was procedurally barred under the applicable rule of civil procedure because Granite “affirmatively declined” live testimony from the witnesses twice. The ALJ explained that Young’s objections were “persuasive” and denied Granite’s request to admit the depositions. ¶27 In early 2020, the parties submitted written closing arguments to the ALJ. In its closing argument, Granite asserted— for the first time—a subrogation claim under Utah Code section 34A-2-106 for the proceeds of Young’s FDCPA settlement. Young countered that “the right to subrogation under 34A-2-106 . . . is an affirmative defense” that Granite waived by failing to properly plead and prove it. ¶28 In July 2020, the ALJ denied Granite’s claim for subrogation and awarded Young historical medical expenses, future medical expenses, and permanent total disability benefits. ¶29 The next month, Granite filed a motion for review with the Labor Commission, arguing that the ALJ erred in three respects, by: (1) refusing to submit Young’s claim to a medical panel, (2) awarding permanent total disability benefits, and (3) refusing to allow a subrogation offset under section 34A-2-106. The Commission agreed with Granite that the question “of which and how much of Ms. Young’s functional limitations are attributable to her work injuries compared to the stress of non-industrial factors represents a significant medical issue” that should have been submitted to an independent medical panel. The Commission accordingly set aside the ALJ’s preliminary award of permanent total disability compensation and remanded the claim for referral to a medical panel. 8 Cite as: 2026 UT 29 Opinion of the Court ¶30 In November 2021, Granite filed a motion for an order to allow additional medical and other records into the evidentiary record. Granite sought to introduce Young’s post-hearing therapy records discussing a 2021 car accident involving Young that allegedly led to the death of a motorcyclist, a news article about the car accident, and a supplemental report from Granite’s psychologist. Young objected. The ALJ denied Granite’s motion, reasoning that “the [Commission] remanded the claim for the medical panel to clarify two specific issues” and it “did not contemplate re-opening the evidentiary record.” ¶31 In February 2023, the ALJ issued interim findings and referred the medical aspects of Young’s case to a medical panel. The ALJ specifically instructed the medical panel to answer the following questions: • “Did the March 14, 2013 industrial accident cause, li[gh]t up, combine with, contribute to, accelerate, prolong, aggravate or make symptomatic ‘the additional stressors including divorce, financial stress, anxiety due to lack of independence, and the stress of understanding her mental condition?’” • “Did the March 26, 2014 industrial accident cause, li[gh]t up, combine with, contribute to, accelerate, prolong, aggravate or make symptomatic ‘the additional stressors including divorce, financial stress, anxiety due to lack of independence, and the stress of understanding her mental condition?’” • “What permanent restrictions, if any, resulted from ‘the additional stressors including divorce, financial stress, anxiety due to lack of independence, and the stress of understanding her mental condition?’” • “With respect to each permanent restriction . . . could you please address whether the restriction is granted for March 14, 2013 industrial injuries, March 26, 2014 industrial injuries or non-industrial causes? Please explain your response.” • “What, if any, functional restrictions assigned by [Young’s second treating physician] are attributable to the March 14, 2013 industrial injuries? Please explain your response.” • “What, if any, functional restrictions assigned by [Young’s second treating physician] are attributable to the March 26, 2014 industrial injuries? Please explain your response.” 9 GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court • “What, if any, functional restrictions assigned by [Young’s second treating physician] are attributable to non-industrial factors? Please explain your response.” ¶32 The medical panel conducted an evaluation and issued a report. The panel noted that Young had restrictions related to ongoing PTSD and anxiety as well as her ability to function in areas of attention, focus, pace, and emotional stability. The panel concluded that all of Young’s functional restrictions related to the two work accidents and that her additional stressors caused only temporary or adjustment reactions and did not contribute to her permanent industrial functional restrictions. ¶33 Granite objected to the medical panel report, arguing that it had “glaring deficiencies due to the excluded medical evidence and other information related to the . . . fatal motor vehicle accident.” The ALJ rejected Granite’s argument, explaining that it “had previously ruled on this issue and denied the motion.” And, relying on the medical panel’s report, the ALJ found “based upon a preponderance of the medical evidence that [Young’s] functional restrictions are based entirely on her industrial medical conditions.” The ALJ accordingly ordered Granite to pay historical medical expenses, future medical expenses, and permanent total disability benefits. ¶34 Granite filed another motion for review with the Labor Commission, arguing that the medical panel’s report was inaccurate and incomplete because “the questions posed by the ALJ failed to clearly instruct the Panel on the analysis it needed to complete.” Because the ALJ “failed to instruct the Panel on what to include as ‘industrial’ and what to include as ‘non-industrial,’” Granite argued that “the Panel’s conclusions clearly include[d] the impact of the tortious debt collection activities and other non- industrial stressors in the impairment it consider[ed] attributable to the industrial accidents.” Granite also asked the Commission to recognize its subrogation interest in Young’s settlement proceeds. The Commission rejected Granite’s arguments and ruled that the medical panel’s report was reliable, that the medical panel understood the issues it was asked to consider, that Young proved the elements of her permanent total disability claim, and that Granite was not entitled to a subrogation offset. The Commission therefore affirmed the ALJ’s award of permanent total disability benefits to Young. 10 Cite as: 2026 UT 29 Opinion of the Court ¶35 Granite petitioned for judicial review, and the court of appeals certified the case to us. We have jurisdiction over cases certified to us by the court of appeals under Utah Code subsection 78A-3-102(3)(a)(ii). ISSUES AND STANDARDS OF REVIEW ¶36 Granite first argues that the Labor Commission erred in instructing the medical panel that reviewed Young’s permanent disability claim. To the extent that Granite challenges the Commission’s interpretation of the charging order, we review for abuse of discretion. UTAH CODE § 63G-4-403(5)(h)(i);3 see, e.g., Danny’s Drywall v. Lab. Comm’n, 2014 UT App 277, ¶ 8, 339 P.3d 624. And to the extent that Granite challenges the admissibility of the report based on allegedly incorrect instructions, we also review for abuse of discretion, reversing “only if a reasonable basis for that decision is not apparent from the record.” Horning v. Lab. Comm’n, 2023 UT App 30, ¶ 18, 529 P.3d 352 (cleaned up). ¶37 Granite next argues that the Labor Commission erred in declining to reopen the evidentiary record. We cannot grant relief unless we determine both that Granite was prejudiced by the Commission’s action, and that the Commission abused its statutorily delegated discretion because its action was contrary to an agency rule, contrary to prior practice, or was otherwise arbitrary or capricious. See UTAH CODE § 63G-4-403(5)(h); cf. Ernest Health, Inc. v. Lab. Comm’n, 2016 UT App 48, ¶¶ 3–9, 369 P.3d 462 (reviewing the Labor Commission’s denial of leave to reopen the evidentiary record for abuse of discretion). ¶38 Granite next argues that the Labor Commission erred in awarding permanent total disability benefits to Young. Generally speaking, “a challenge to an administrative agency’s finding of fact is reviewed for substantial evidence.” Provo City v. Utah Lab. Comm’n, 2015 UT 32, ¶ 8, 345 P.3d 1242; see also UTAH CODE § 63G- 4-403(5)(g). “A decision is supported by substantial evidence if there is a quantum and quality of relevant evidence that is adequate to convince a reasonable mind to support a conclusion.” Provo City, 2015 UT 32, ¶ 8 (cleaned up). But as explained in greater detail __________________________________________________________ 3 While the 2024 version of the Utah Code applies and the legislature has made some subsequent changes to the code, no substantive changes are applicable here, nor do any of the changes impact our analysis. Thus, we cite the current version of the code throughout this opinion for both convenience and clarity. 11 GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court below, some elements are mixed questions and warrant a different standard of review. Id. ¶¶ 12–22. ¶39 Finally, Granite argues that the Labor Commission erred in refusing to grant a subrogation offset under Utah Code section 34A-2-106. We review an agency’s interpretation of a statute for correctness. LPI Servs. v. McGee, 2009 UT 41, ¶ 7, 215 P.3d 135; see also Esquivel v. Lab. Comm’n, 2000 UT 66, ¶¶ 13–19, 7 P.3d 777. “And we review the lower tribunal’s ultimate conclusion of whether a given set of facts comes within the reach of a given rule of law as a mixed question of law and fact.” Gamez v. Utah Lab. Comm’n, 2022 UT 20, ¶ 23, 511 P.3d 1145 (cleaned up). ANALYSIS I. GRANITE HAS NOT CONVINCED US THAT THE MEDICAL PANEL WAS WRONGLY INSTRUCTED ¶40 Granite first asserts that the Labor Commission failed to instruct the medical panel to distinguish which of Young’s limitations were a result of work accidents as opposed to non- industrial stressors. In Granite’s view, the deficient instructions resulted in a flawed report that should not have been relied upon by the ALJ or the Commission. Young responds that the instructions were sufficiently detailed and that the panel clearly differentiated between the industrial injuries and the non- industrial stressors. We agree with Young. ¶41 The ALJ’s questions to the panel asked it to parse the impact of the 2013 work accident, the 2014 work accident, and the stress of non-industrial factors—“divorce, financial stress, anxiety due to lack of independence, and the stress of understanding her mental condition”—on Young’s ability to work. ¶42 The panel answered that all of Young’s functional restrictions stemmed from the work accidents. The other stressors, the panel opined, caused only temporary or adjustment reactions and did not contribute to her permanent industrial functional restrictions. Relying on the medical panel’s report, the ALJ ultimately found by “a preponderance of the medical evidence that [Young’s] functional restrictions are based entirely on her industrial medical conditions.” And the Labor Commission “concur[red] with [the ALJ’s] decision to rely on the panel’s conclusions regarding the work-relatedness of Ms. Young’s limitations.” 12 Cite as: 2026 UT 29 Opinion of the Court ¶43 So, the ALJ instructed the panel to separate out the impacts of the two work accidents from other life stressors, and the panel said that the work accidents on their own were permanently debilitating, while the impact from other stressors was passing and noncontributory. On judicial review, Granite has pointed to no authority—and we are aware of none—suggesting that the ALJ was required to instruct the panel more granularly than it did. Therefore, we decline to set aside the Labor Commission’s award on this basis. II. THE ALJ DID NOT ABUSE ITS DISCRETION BY DENYING GRANITE’S MOTION TO REOPEN THE EVIDENCE ¶44 Granite next asserts that the Labor Commission erred in upholding the ALJ’s decision not to reopen the evidentiary record. Granite sought to introduce evidence about Young’s federal debt collection lawsuit discussed above and her involvement in a car accident years after the hearing. In response, Young asserts that the ALJ acted within its discretion in declining to reopen the record. Again, we agree with Young. ¶45 The administrative code provides that “the evidentiary record shall be deemed closed at the conclusion of the hearing, and no additional evidence will be accepted without leave of the administrative law judge.” UTAH ADMIN. CODE R602-2-1(I)(8). This provision—particularly the phrase “leave of the administrative law judge,” id.—suggests that the decision of whether to reopen the evidentiary record after a hearing is a discretionary one left to the ALJ. The noun “leave” is commonly understood to mean “[p]ermission.” Leave n., BLACK’S LAW DICTIONARY (12th ed. 2024); see also Leave of Court, BLACK’S LAW DICTIONARY (12th ed. 2024) (defining “leave of court” as “[j]udicial permission to follow a nonroutine procedure”). ¶46 Reviewing a decision to not grant a party leave to reopen the evidentiary record for an abuse of discretion also makes logical sense. The Labor Commission generally has discretion over how to investigate each case. Under Utah Code subsection 34A-2-802(1), “The commission may make its investigation in such manner as in its judgment is best calculated to ascertain the substantial rights of the parties and to carry out justly the spirit of the chapter.” In this vein, the court of appeals has reviewed the Labor Commission’s denial of a motion to reopen the evidentiary record for an abuse of discretion. See Ernest Health, Inc. v. Lab. Comm’n, 2016 UT App 48, ¶¶ 3–9, 369 P.3d 462. And we cannot grant relief unless we 13 GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court determine both that Granite was prejudiced by the Commission’s action and that the action was an abuse of the Commission’s statutorily delegated discretion, contrary to an agency rule, contrary to prior practice, or otherwise arbitrary or capricious. See UTAH CODE § 63G-4-403(5)(h). ¶47 The question before us, then, is whether the ALJ abused its discretion in declining to reopen the evidentiary record at Granite’s requests. The hearing was held on August 23, 2019, after which the ALJ ordered the record to “remain open for a period of twenty days . . . to permit Granite School District to file its expert medical opinion.” But Granite did not file its expert medical opinion or make its requests to reopen the record within that twenty-day window. Instead, Granite’s two requests to reopen the evidentiary record were made two months and two years after the hearing, respectively. The ALJ agreed with Young first that Granite was procedurally barred from admitting depositions of witnesses after it declined live testimony and second that the Commission “remanded the claim for the medical panel to clarify two specific issues” and it “did not contemplate re-opening the evidentiary record.” ¶48 Like all things, the presentation of evidence must come to an end sometime, and the ALJ did not abuse its discretion by drawing the line where it did, particularly where the medical panel found that the debt collection efforts explored in the depositions sought to be admitted did not meaningfully contribute to Young’s condition. And some of the evidence Granite sought to introduce (like the car accident) was irrelevant anyway because it related to events after both the hearing and the ALJ’s finding of permanent and total disability. Young’s condition thereafter could not become either more permanent or more total. ¶49 Our administrative code gives an ALJ discretion over whether to grant a party leave to reopen the evidentiary record. Under the circumstances here, Granite has not persuaded us that the Labor Commission erred in upholding the ALJ’s discretionary call. III. THE LABOR COMMISSION’S PERMANENT TOTAL DISABILITY AWARD STANDS ¶50 Granite next argues that the Labor Commission erred in awarding Young permanent total disability benefits. Specifically, Granite challenges the Commission’s findings on five of the six elements of Young’s permanent total disability claim. 14 Cite as: 2026 UT 29 Opinion of the Court ¶51 Utah Code subsection 34A-2-413(1) states the elements of a permanent total disability claim. The permanent total disability statute requires workers to prove six elements “by a preponderance of the evidence”: (1) “the employee sustained a significant impairment or combination of impairments as a result of the industrial accident . . . that gives rise to the permanent total disability entitlement”; (2) “the employee is not gainfully employed”; (3) “the employee has an impairment or combination of impairments that reasonably limit the employee’s ability to do basic work activities”; (4) “the . . . impairment or combination of impairments prevent the employee from performing the essential functions of the work activities for which the employee has been qualified until the time of the industrial accident . . . that is the basis for the employee’s permanent total disability claim”; (5) “the employee cannot perform other work reasonably available, taking into consideration the employee’s: (A) age; (B) education; (C) past work experience; (D) medical capacity; and (E) residual functional capacity”; and (6) “the industrial accident or occupational disease is the direct cause of the employee’s permanent total disability.” UTAH CODE § 34A-2-413(1)(b)–(c); see also Provo City v. Utah Lab. Comm’n, 2015 UT 32, ¶ 6, 345 P.3d 1242. ¶52 “It is well settled that when faced with a question of statutory interpretation, our primary goal is to evince the true intent and purpose of the legislature.” Anderson v. Utah Dep’t of Com., 2025 UT 19, ¶ 14, 572 P.3d 373 (cleaned up). In doing so, “we begin by looking at the plain language of the statute itself,” and “when the meaning of a statute can be discerned from its language, no other interpretive tools are needed.” Id. (cleaned up). Further, “we assume, absent a contrary indication, that the legislature used each term advisedly according to its ordinary and usually accepted meaning.” Marion Energy, Inc. v. KFJ Ranch P’ship, 2011 UT 50, ¶ 14, 267 P.3d 863 (cleaned up). ¶53 We uphold an agency’s factual findings so long as they are supported by “substantial evidence when viewed in light of the whole record.” UTAH CODE § 63G-4-403(5)(g). “A decision is 15 GRANITE SCHOOL v. LABOR COMMISSION Opinion of the Court supported by substantial evidence if there is a quantum and quality of relevant evidence that is adequate to convince a reasonable mind to support a conclusion.” Provo City, 2015 UT 32, ¶ 8 (cleaned up). “In conducting a substantial evidence review, we do not reweigh the evidence and independently choose which inferences we find to be the most reasonable”; rather, “we defer to an administrative agency’s findings because when reasonably conflicting views arise, it is the agency’s province to draw inferences and resolve these conflicts.” Id. (cleaned up). ¶54 Granite has challenged the Commission’s findings on five of the six elements of Young’s permanent total disability claim.4 We analyze each of these elements in turn and conclude that there was substantial evidence in the record to support Young’s permanent total disability claim. A. Significant Impairment ¶55 The Labor Commission determined that Young suffered a significant impairment or combination of impairments from the industrial accidents. In support of this determination, the Commission relied on the second treating physician’s report indicating that Young “had functional limitations that interfered with her ability to recognize and correct mistakes, use reason and judgment to make work-related decisions, and work at an appropriate and consistent pace, among other things.” Granite takes issue with this determination, arguing that because no treating physician has provided Young with an impairment rating, her subjective complaints of impairment cannot satisfy this element. Granite also suggests that there is not substantial evidence to support the Commission’s impairment determination and that Young’s limitations were really from non-industrial factors.5 __________________________________________________________ 4 The Labor Commission found that Young “cannot perform other work reasonably available considering her age, education, past work experience, medical capacity, and residual functional capacity.” Granite has not challenged that finding on review, so we do not analyze it. 5 In Provo City v. Utah Labor Commission, we explained that this element presents a mixed question of law and fact. 2015 UT 32, ¶ 16, 345 P.3d 1242. Granite’s argument that the permanent total disability statute requires an impairment rating presents a (continued . . .) 16 Cite as: 2026 UT 29 Opinion of the Court ¶56 Granite is mistaken on both points. The permanent total disability statute requires an employee to show that “the employee sustained a significant impairment or combination of impairments . . . that gives rise to the permanent total disability entitlement.” UTAH CODE § 34A-2-413(1)(b)(i). As our court of appeals has previously concluded, the statute does not require a precise impairment rating. See Rouse v. Lab. Comm’n, 2024 UT App 77, ¶ 35, 551 P.3d 1014 (“U