Supreme Court of Missouri / Apr 29, 2025
James Eckardt, Appellant/Cross-Respondent, vs. Treasurer of Missouri as Custodian of the Second Injury Fund, Respondent/Cross-Appellant.
James Eckardt appealed the Labor and Industrial Relations Commission's denial of permanent total disability (PTD) benefits from the Second Injury Fund. Eckardt argued the Commission misconstrued evidence regarding his right shoulder injury and erred by not applying a load factor to enhance its permanent partial disability (PPD) rating. The Court affirmed the Commission's decision, holding that the load factor analysis was eliminated by statutory amendments and that Eckardt failed to prove PTD based solely on qualifying preexisting injuries.