Angela Jones v. Mississippi Baptist Health Systems, Inc. and Mississippi Baptist Health Services
The Mississippi Supreme Court recently overturned a decision by the Mississippi Court of Appeals. The Supreme Court’s decision is important because it reinforces the 2012 legislative amendment that abolished the claimant-favoring standard of the MS Workers’ Compensation Act. The decision also reaffirms well-established law that the Commission is the ultimate fact finder in workers’ compensation cases and that the Commission’s decisions should not be judicially disturbed where there is no error of law and where there is “substantial credible evidence that support’s the Commission’s decision.”
We encourage you to read the facts of the case. However, to briefly summarize the facts, Claimant, a registered nurse, repeatedly failed to report a specific work injury to either her healthcare providers or the Employer. Further, there was a lack of medical evidence from her treating physicians affirmatively relating the condition to her work incident.
At the compensability hearing, Administrative Judge Lott found that a preponderance of the evidence supported a finding that Claimant sustained a work injury on March 21, 2015. The Employer and Carrier appealed Administrative Judge Lott’s Order to the Full Commission. The Full Commission found that Claimant failed to meet her burden of proving a work related injury and entered an order reversing Administrative Judge Lott’s decision. Claimant appealed the Full Commission’s decision and the case was assigned to the Mississippi Court of Appeals.
A divided Mississippi Court of Appeals reversed the Commission’s decision “because the evidence presented does not contradict [Claimant’s] testimony concerning the mechanism of injury. . . [and] the Commission erred by disregarding Claimant’s evidence.” The Court supported its decision, in part, by citing pre-2012 amendment case law that stood for the proposition that an error of law exists when the Commission fails to carry out the beneficent intent and purpose of the Workers’ Compensation Act. Further, the Court of Appeals cited case law that supported the proposition that the Workers’ Compensation Act is to be construed liberally in favor of claimants.
However, Jack Wilson, Presiding Judge of the Mississippi Court of Appeals, dissented from the majority and wrote a separate written opinion and pointed out that “none of that is the law anymore” following the 2012 amendments. Judge Wilson argued that the majority’s opinion was based on a clear misstatement of law and the Commission’s decision must be affirmed because it was supported by substantial, competent evidence from multiple sources.
The Employer and Carrier appealed the Court of Appeals decision to the Mississippi Supreme Court. The Supreme Court ultimately concluded that the Commission’s decision was supported by substantial evidence because the Commission based its decision on Claimant’s treating physicians’ opinions, Claimant’s testimony, and Claimant’s failure to report her specific work related injury to her medical providers and her Employer. Further, the Mississippi Supreme Court agreed with Presiding Judge Jack Wilson’s dissenting opinion and found the Court of Appeals committed “serious error” by ignoring the 2012 amendment that legislatively abolished the claimant-favoring standard.
It is important to note that the Mississippi Supreme Court unanimously agreed that the Court of Appeals erred by applying a claimant-favoring standard that was abolished by the Legislature in 2012. However, Presiding Justice Kitchens wrote a dissenting opinion arguing that the Commission’s decision should be reversed nonetheless because the Commission’s decision was unsupported by substantial evidence and was arbitrary and capricious.