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Hope Livestock Auction Co. v. Knighton
Citations: 62 Ark. App. 74; 966 S.W.2d 943; 1998 Ark. App. LEXIS 329Docket: CA 97-1314
Court: Court of Appeals of Arkansas; May 6, 1998; Arkansas; State Appellate Court
Hope Livestock Auction Company appeals a Workers’ Compensation Commission decision affirming an administrative law judge's (ALJ) finding that the company is responsible for Johnny Knighton's bipolar disorder and prior back injuries. The court reverses and remands for a required finding of fact under Ark. Code Ann. section 11-9-113. Knighton has a history of job-related injuries starting in 1981, including multiple back surgeries performed by Dr. George Bohmfalk and a diagnosis of bipolar I disorder by Dr. Tobey. Medical costs related to Knighton's conditions were covered by the appellant or associated insurers. Following a 1995 incident where Knighton was injured by a cow, he continued to work until July 1996, when he could no longer handle his job due to his mental illness. The ALJ ordered the appellant to pay temporary total disability benefits and Knighton's medical bills, while stating that CNA Insurance Company would cover additional costs from the 1995 incident. On appeal, the appellant contests the findings regarding the compensability of Knighton's mental injury, entitlement to additional disability benefits, and the nature of the aggravation of his condition, arguing that these findings lack substantial evidence. The court finds the first argument compelling, reversing and remanding on that basis, and determines that the other arguments need not be considered. The court's review assesses whether the Commission's decisions are supported by substantial evidence, defined as relevant evidence a reasonable mind would accept to support a conclusion. In Wright v. ABC Air, Inc., the Arkansas Court of Appeals addressed the issue of whether the Commission's finding that Knighton's bipolar disorder was compensable was supported by substantial evidence. The appellant contended that Knighton failed to establish the prima facie elements of his claim, particularly under Ark. Code Ann. § 11-9-113, which mandates that a mental injury or illness must be diagnosed by a licensed psychiatrist or psychologist and conform to the Diagnostic and Statistical Manual of Mental Disorders (DSMD). The court noted the absence of testimony confirming that Knighton's diagnosis met DSMD criteria and determined that the Commission improperly conducted an extrajudicial review of documentation not presented as evidence. The court emphasized the need for strict construction of workers' compensation statutes and impartial evidence weighing by the ALJ and Commission. Consequently, the court reversed the Commission's decision and remanded the case for further findings. Judges Rogers and Meads concurred with the decision.