Jonathan Parker Missouri Cases

The Second Injury Fund appealed the Labor and Industrial Relations Commission's award of permanent total disability benefits to Jonathan Parker. The Missouri Supreme Court found that the Commission erred by applying the incorrect subsection of section 287.220, as Parker's injuries occurred after January 1, 2014, requiring application of subsection 3. The Court provided statutory interpretations for the Commission to apply on remand and addressed an evidentiary issue regarding the admissibility of medical records. The Court vacated the Commission's award and remanded the case for a determination under the correct statutory provisions.

Jonathan Parker, a manual laborer, filed a workers' compensation claim against the Second Injury Fund after sustaining a neck injury, arguing he was permanently and totally disabled due to a combination of his work injuries and preexisting conditions. The Labor and Industrial Relations Commission found the Fund liable. On appeal, the Fund argued the Commission applied the wrong statute and improperly considered Parker's less serious preexisting injuries. The appellate court affirmed, holding that while the Commission initially applied the wrong statute, the record supported Fund liability under the correct statute, and the Commission could consider all of Parker's characteristics, including less serious preexisting injuries, when determining total disability.