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Jered Industries, Inc. v. Pearson
Citations: 261 Ga. App. 373; 582 S.E.2d 522; 2003 Fulton County D. Rep. 1639; 2003 Ga. App. LEXIS 634Docket: A03A0678
Court: Court of Appeals of Georgia; May 22, 2003; Georgia; State Appellate Court
Stanley Pearson sustained a work-related back injury while employed at Jered Industries, Inc., and sought a catastrophic injury designation, which was contested by his employer and insurer, American Home Assurance Company. An administrative law judge (ALJ) ruled the injury was not catastrophic, a decision upheld by the appellate division. Pearson appealed to the superior court, which reversed the Board’s decision. The court's review emphasized that appellate courts must favor the evidence supporting the Board’s findings, which are conclusive when backed by any evidence. In October 1994, Pearson injured his back and underwent three surgeries, after which he returned to a light duty role but experienced increased pain and stopped working three weeks later. In February 1999, his physician, Dr. Gold, deemed him permanently and totally disabled. Pearson later received social security disability benefits in December 1999 and petitioned for rehabilitation services in July 2000, which led to a contested hearing regarding the catastrophic designation. A functional capacity examination indicated that, although Pearson could not return to his assembly job, he was capable of sedentary work. Dr. Gold concurred with Dr. Muenz’s assessment that Pearson could perform light duty work. Consequently, the ALJ concluded Pearson’s injury was not catastrophic, a finding supported by the appellate division. The definition of a catastrophic injury under OCGA § 34-9-200.1 (g) includes injuries qualifying for social security disability benefits, which creates a rebuttable presumption of catastrophic injury. The State Board found that the Employer/Insurer successfully rebutted this presumption, a conclusion the superior court disputed. However, given the evidence of Pearson's ability to perform sedentary work, the appellate courts found sufficient grounds to uphold the Board's decision. The superior court's decision to reverse the award regarding Pearson's injury classification as noncatastrophic is affirmed. The case was decided on May 22, 2003, with McLain, Merritt, Holcomb, and Jones representing the appellants, and Crowe for the appellee. The judgment was reversed with concurrence from Chief Justice Smith and Justice Miller. The Social Security Administration recognized Pearson's entitlement to benefits retroactive to March 1998, as stipulated under the pre-1995 version of OCGA § 34-9-200.1 (g), despite subsequent amendments. The ruling cites the necessity for an administrative law judge (ALJ) to determine if the presumption of catastrophic injury was effectively rebutted. Generally, the award of social security disability benefits indicates an inability to perform substantial gainful activity due to a medically determinable impairment expected to last at least 12 months. In appeals regarding workers’ compensation awards, the superior court lacks the authority to reassess evidence or evaluate witness credibility.