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Dura Craft Boats, Inc. v. Daugherty

Citations: 253 Ark. 340; 485 S.W.2d 739; 1972 Ark. LEXIS 1464Docket: 5-6039

Court: Supreme Court of Arkansas; October 23, 1972; Arkansas; State Supreme Court

Narrative Opinion Summary

In this case, a riveter employed by the appellant sustained an injury to his right hand, which the Workmen’s Compensation Commission assessed as resulting in a 10% permanent partial disability to the hand. The circuit court, however, revised this finding, awarding compensation for a 10% permanent partial disability to the body as a whole. On appeal, the court emphasized its limited role in reviewing the Commission’s factual determinations, focusing solely on whether there was substantial evidence to support the Commission's original decision. The appellee’s medical expert suggested overall bodily impairment, yet also highlighted specific sensory changes in the right hand, while the appellant's expert found no impediment to normal work activities. The appellate court determined that substantial evidence justified the Commission's determination, thus reversing the circuit court's judgment and remanding the case with instructions to reinstate the Commission’s original award for the hand injury. This decision underscores the principle that appellate courts should not supplant the factual findings of specialized commissions when substantial evidence exists.

Legal Issues Addressed

Judicial Review of Commission's Factual Findings

Application: The circuit court erred in substituting its own judgment for that of the Commission by awarding compensation for a disability to the body as a whole.

Reasoning: The circuit court, upon appeal, reversed this decision, granting compensation for a 10% permanent partial disability to the body as a whole instead.

Role of Appellate Courts in Workmen’s Compensation Cases

Application: The appellate court's role is limited to determining whether there is substantial evidence to support the Workmen’s Compensation Commission's findings, not to make its own factual determinations.

Reasoning: The role of an appellate court is limited to assessing whether substantial evidence supports the Commission's findings, without making its own factual determinations.

Substantial Evidence Standard in Workmen’s Compensation

Application: The appellate court found substantial evidence supporting the Commission’s finding of a 10% permanent partial disability to the right hand, based on the testimony regarding the appellee's injury and subsequent employment.

Reasoning: Given the evidence and its favorable interpretation towards the Commission's findings, the appellate court concluded that substantial evidence supported the Commission's original determination.