Missouri Court of Appeals, Western District / Sep 4, 2018
AB Electrical, Inc. vs. Joseph Franklin
AB Electrical, Inc. appealed a temporary award of worker's compensation benefits to Joseph Franklin by the Labor and Industrial Relations Commission. The Commission had reversed an Administrative Law Judge's decision, finding the employer failed to prove Franklin's drug use proximately caused his injury. The appellate court dismissed the appeal for lack of a final judgment, holding that it lacked statutory authority to review a temporary award of temporary total disability benefits under the strict construction mandate of the 2005 amendments to the Worker's Compensation Law, and expressly overruling prior Western District precedent.