An appeals court in Missouri overturned a workers’ compensation decision that denied coverage for a high school teacher’s injuries. The reasons why the workers’ compensation was originally denied, though, raises some serious questions about how these cases are being decided in Missouri.
High School Teacher Falls, Gets Hurt, and Is Denied Workers’ Compensation
On January 8, 2013, an ESL teacher reported for work at her high school in Missouri. After parking her car, crossing the parking lot, opening the main doors to the school, and taking a few steps inside, she slipped and fell.
There were no mats on the tile floors of the hallway, even though the parking lot was wet from recent snow, sanded and salted.
The injuries she suffered proved to be severe enough to keep her out of work afterwards.
When she filed for workers’ compensation for both temporary total and permanent partial disability benefits, she was denied by the administrative law judge.
That administrative judge said that the teacher “failed to provide credibly testimony.” In her accident report, she said she could not identify the cause of her fall. In her testimony, though, she said that the floor was wet and dirty and did not have mats, but only after her attorney asked her about it.
Commission Affirms Denial of Workers’ Compensation
When she appealed the denial to the Labor and Industrial Relations Commission, the denial got affirmed. The judges there agreed with the administrative judge that the teacher was not credible.
The teacher appealed.
Appeals Court Overturns Decision
Because the appeal involved a whether she was credible or not, the Missouri Court of Appeals had a very high standard for her to prove: It would affirm the Commission’s denial unless it was unsupported by evidence. Appeals courts recognize that they are not seeing or hearing the testimony, putting them in a bad position to judge its credibility. Therefore, most appeals based on someone’s credibility fail.
This one, though, succeeded because of how terrible the earlier decisions had been.
Looking at the transcript of the teacher’s testimony, the Court of Appeals found that the reasons for the teacher lacking credibility took everything out of context:
- The Commission made much of the fact that medical records did not say why the teacher fell. The Court of Appeals pointed out that medical records never include those details.
- The Commission claimed the teacher went from saying the floor was “normal” to saying it was dirty, icy, and wet. The Court of Appeals pointed out that the first question asked about the floor’s physical condition, while the second asked about what was on the floor when she fell.
The Court of Appeals used a harsh label for the Commission’s decision that the teacher should not be believed: It was “arbitrary.”
St. Joseph Workers’ Compensation Lawyers at the Smith Law Office
Decisions like these by the Labor Commission and administrative law judges are disturbing because they take the “strict construal” of workers’ compensation laws to an extreme, looking for any reason – good or bad – to deny a claim.