WAYNE COUNTY, MISSOURI, Employer-Appellant and MISSOURI ASSOC. of COUNTIES, Insurer- Missouri Cases

Wayne County and its insurer appealed a circuit court judgment ordering them to pay workers' compensation benefits to Amie Elsworth, the widow of an employee who died after sustaining a work-related injury. The employer argued that Elsworth's entitlement to benefits under the Schoemehl doctrine was not raised or adjudicated by the Labor and Industrial Relations Commission. The appellate court affirmed, holding that the Commission's factual findings, which were affirmed in a prior appeal, implicitly resolved the Schoemehl issue, making the circuit court's entry of judgment a ministerial act.