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Syntec Industries, Inc. v. Godfrey
Citations: 269 Ga. 170; 496 S.E.2d 905; 98 Fulton County D. Rep. 815; 1998 Ga. LEXIS 342Docket: S97A1511
Court: Supreme Court of Georgia; March 9, 1998; Georgia; State Supreme Court
The court granted a discretionary appeal to evaluate OCGA § 34-9-103(a) (as amended in 1994) regarding its compliance with due process. The key issues included whether the statute improperly shifts the burden of proof on appeal to a party who did not bear it before the administrative law judge (ALJ), whether the appellate division has the authority to weigh evidence and assess witness credibility, and whether such authority violates due process. The court concluded that the statute does not shift any burden of proof and that the appellate division did not impose any burden on Syntec Industries. It reaffirmed that OCGA § 34-9-103(a) allows the appellate division to weigh evidence and judge credibility, declining to address Syntec's constitutional challenge due to its failure to raise the issue in earlier proceedings. The statute mandates that upon timely application for review, the appellate division must review the evidence and issue findings of fact and conclusions of law. The appellate division is permitted to remand cases to the ALJ for corrections or additional evidence consideration, while also being required to accept the ALJ’s findings if supported by credible evidence. The court clarified that the statute does not place a burden on a prevailing party to prove the ALJ's award was supported by evidence, but rather establishes a standard of review. It emphasized that the claimant retains the burden of proving a compensable injury, and the employer does not bear the burden to disprove entitlement. Finally, the court noted that if the appellate division substitutes its findings for those of the ALJ, a superior court must affirm if evidence supports the appellate division's findings. The judgment of the trial court was affirmed. The superior court is required to affirm the appellate division's decisions when supported by evidence, similar to how the appellate division must affirm the ALJ’s findings based on a preponderance of credible evidence. However, the appellee does not bear the burden of proof on appeal to show that evidence supports the appellate division's findings. The record indicates that the appellate division did not improperly shift the burden of proof to Syntec. Additionally, Syntec did not previously argue that OCGA § 34-9-103 violated due process by allowing the appellate division to evaluate evidence and witness credibility, preventing them from raising this issue on appeal. The judgment is affirmed, with all Justices in agreement.