Spencer v. Tyson Foods, Inc.
| Docket Number: | 2003-WC-00805-COA | |
| Oral Argument: | 01-20-2004 | |
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| Court of Appeals: |
Opinion Date: 04-06-2004 Opinion Author: GRIFFIS, J. Holding: Reversed and Rendered |
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| Additional Case Information: |
Topic: Workers' compensation - Substantial evidence Judge(s) Concurring: McMILLIN, C.J., KING AND SOUTHWICK, P.JJ., BRIDGES, THOMAS, LEE, IRVING, MYERS AND CHANDLER, JJ. Procedural History: Admin or Agency Judgment Nature of the Case: CIVIL - WORKERS' COMPENSATION |
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| Trial Court: |
Date of Trial Judgment: 03-10-2003 Appealed from: Hinds County Circuit Court Judge: W. Swan Yerger Disposition: REVERSED COMMISSION'S FINDING OF COMPENSABLE INJURY |
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| Party Name: | Attorney Name: | |||
| Appellant: | DELORES SPENCER |
JOHN GRIFFIN JONES
AUBREY HORACE BREWER |
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| Appellee: | TYSON FOODS, INC. | MICHELLE BARLOW MIMS JAMES RYAN PERKINS DANIEL M. BAKER |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Workers' compensation - Substantial evidence |
| Summary of the Facts: | Delores Spencer claimed that she was injured while working at the Tyson Foods, Inc. chicken processing plant. The Mississippi Workers' Compensation Commission granted disability benefits. Tyson appealed to the circuit court which reversed the Commission’s award. Spencer appeals. |
| Summary of Opinion Analysis: | Spencer argues that the court erred in its conclusion that the Commission’s decision was not supported by substantial evidence. Under the Mississippi Workers' Compensation Act, an injury may be accidental although it occurs in the usual course of employment and involves only the usual exertion. Spencer's MRI indicated the she had spondylosis, and the medical evidence established that spondylosis can be aggravated by repetitive motions such as those required by Spencer's work. Therefore, there was substantial evidence before the Commission to support its conclusion that Spencer's injury met the definition of an accidental injury under the Act. With regard to whether the injury was work-related, the exact cause of Spencer’s primary medical problem could not be, ascertained. However, all three doctors who treated Spencer opined that her work aggravated her spondylosis, thereby contributing to the injury. Therefore, there was substantial evidence to support the Commission’s finding that Spencer’s employment was a substantial contributing cause of her disability. With regard to whether there was a causal connection between the injury and the disability, the Commission had conflicting evidence that supported the positions taken by both Spencer and Tyson. Because substantial evidence did in fact exist to support the Commission’s finding. The circuit court erred when it reweighed the evidence. |
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