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Reather v. Ward Furniture Mfg. Co.
Citations: 238 Ark. 53; 378 S.W.2d 201; 1964 Ark. LEXIS 533Docket: 5-3222
Court: Supreme Court of Arkansas; May 4, 1964; Arkansas; State Supreme Court
Ed. F. McFaddin, Associate Justice, outlines the procedural history of Mr. Reather's workmen's compensation claim against Ward Furniture Manufacturing Company. Mr. Reather, employed by the company, collapsed at work on September 26, 1956, alleging an accidental injury due to breathing dust, leading him to file a compensation claim. The Workmen's Compensation Commission initially ruled in his favor on November 10, 1959, but the employer appealed to the Sebastian Circuit Court, which vacated the award and remanded for further testimony. After additional evidence was presented, the Commission denied the claim on August 31, 1960. The Circuit Court vacated this denial on December 15, 1960, leading to an appeal by the employer. The Arkansas Supreme Court affirmed the Circuit Court's judgment. Subsequently, the Commission reopened the case, and Mr. Reather underwent examinations, including one by Dr. Grimsley Graham, who provided a report. The Commission ultimately denied Mr. Reather's claim on July 26, 1963, stating he did not establish a causal connection between his employment and his disability. The Circuit Court affirmed this decision on October 24, 1963. The current appeal hinges on whether substantial evidence supports the Commission’s findings. Mr. Reather must prove that his work conditions contributed to his collapse; the burden of proof lies with him, as established in relevant case law. The Commission's finding that he failed to demonstrate this causal connection is now under scrutiny. Dr. Graham conducted an examination of Mr. Reather and reported his findings in a letter dated June 5, 1962, to the Commission, which received no objections. He diagnosed Mr. Reather with bronchiectasis and noted chest x-ray findings of generalized emphysema and interstitial fibrosis. When asked about a potential causal link between Mr. Reather's pulmonary condition and his work environment, Dr. Graham asserted that bronchiectasis is not typically caused by occupational exposure but often originates in childhood, potentially following illnesses like whooping cough or pneumonia, which Mr. Reather experienced in the 1920s. Dr. Graham concluded that exposure to work-related dust did not contribute to or exacerbate Mr. Reather’s pre-existing pulmonary condition and that any aggravation from dust exposure would have ceased upon removal from that environment. Consequently, Dr. Graham's testimony indicated no causal connection between Mr. Reather’s employment and his disability, leading the Commission to deny Mr. Reather's claim. Dr. Graham's report was deemed substantial evidence supporting the Commission's decision, resulting in the Circuit Court's affirmation of that decision. The judgment was affirmed, with Judges Ward and Johnson dissenting.