Court: Supreme Court of Arkansas; February 2, 1953; Arkansas; State Supreme Court
Jesse Stovall, the appellee, experienced back pain on September 1, 1950, which he attributed to his employment with Stallings Bros. Feed Mill. Initially, his claim for compensation was rejected by the Workmen’s Compensation Commission. The Circuit Court later reversed this decision, prompting the employer to appeal. The trial judge concluded that the Commission's findings lacked substantial evidence, emphasizing that the Commission's determinations should be upheld if backed by such evidence. The court's focus was not on what it would have decided but on whether the Commission's findings were supported by substantial evidence.
Stovall, a 50-year-old employee who had been with the company for about five years, had duties that included delivering 100-pound sacks of feed. On the day of the alleged injury, while delivering sacks with a helper, he experienced leg pain that intensified, leading him to drop a sack and cease assistance. Despite the pain, he completed his route but did not work thereafter. An operation on October 17, 1950, revealed a ruptured disc, with medical testimony suggesting that his job duties could have caused the condition.
However, conflicting evidence existed, including the employer’s report which noted a lack of a specific accident and Stovall's prior statements indicating no unusual strain during his work. Additionally, he had mentioned experiencing pain while driving and prior to starting work that day. This contradictory evidence was crucial for the Commission's evaluation, which had the exclusive right to assess the credibility and weight of the testimony presented.
Appellee had a history of health issues, including hip and kidney problems, and previously sought chiropractic treatment for back pain in 1949, leading to approximately thirty days of lost work. Legal precedents indicate a divergence in whether an accidental incident is necessary for an award from the Commission. Some cases suggest that no such incident is required, while others assert that an accident must be present for recovery. The definition of 'injury' under the 1948 Initiated Act No. 4 specifies that it pertains only to accidental injuries occurring in the course of employment. The perceived inconsistencies in case law are deemed more semantic than substantive, with the conclusion that each case should be evaluated based on its unique facts. Ultimately, the Commission determined that the claimant's back and leg conditions, which arose after September 1, 1950, were not attributable to an accidental injury linked to his employment. This finding is supported by substantial evidence, leading to the reversal of the trial court's decision and reinstatement of the Commission's ruling.
