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Satterfield v. Timken SMO, LLC(2021)
February 22, 2021#17-011298
The Commission affirmed the administrative law judge's award allowing workers' compensation for employee Martha Satterfield's work-related injuries to her abdomen and right foot. One commissioner dissented, disagreeing with the interpretation that the employee failed to establish liability against the Second Injury Fund for permanent total disability.
Chambers v. City of Galena(2021)
February 22, 2021#15-088178
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award denying workers' compensation benefits to James Chambers, finding he was not permanently and totally disabled despite physical impairments. One commissioner dissented, arguing the employee could not compete in the open labor market given medical restrictions requiring periodic rest.
Satterfield v. Carlisle Transportation Products, LLC(2021)
February 22, 2021#15-104637
The Commission affirmed the administrative law judge's award allowing workers' compensation for Martha Satterfield's work-related injuries to her abdomen and right foot. One member dissented, arguing the judge applied too narrow an interpretation of Second Injury Fund liability by not considering the combined effect of multiple preexisting conditions with the subsequent work-related injuries.
Zeschke v. Missouri Department of Corrections(2021)
February 22, 2021#09-022905
The Labor and Industrial Relations Commission affirmed the administrative law judge's award denying compensation to Judy Zeschke for her workers' compensation claim involving a March 31, 2009 ankle injury and pre-existing carpal tunnel syndrome. One commissioner dissented, arguing that the Second Injury Fund should be liable for permanent partial disability based on the synergistic effects of the employee's multiple pre-existing conditions combined with the ankle injury.
Marberry v. Alan Marberry(2021)
February 19, 2021#15-083958
The Commission affirmed the administrative law judge's award denying workers' compensation benefits in a case involving a 2015 injury with preexisting conditions. One commissioner dissented, arguing that the employee's preexisting disabilities combined with the subsequent injury should qualify for Second Injury Fund liability for permanent total disability benefits.
Cox v. Missouri Department of Corrections(2021)
February 19, 2021#15-015561
The Labor and Industrial Relations Commission affirmed the administrative law judge's award of workers' compensation benefits to Ronald Cox for a work-related injury sustained on March 13, 2015. One commission member dissented, arguing the award should be modified to reflect only a 4% permanent partial disability based on objective medical evidence.
Polston v. State of Missouri, Fulton State Hospital(2021)
February 11, 2021#14-078566
The Labor and Industrial Relations Commission affirmed the administrative law judge's award denying workers' compensation benefits, finding that the employee was not permanently and totally disabled from the October 2014 work injury alone or in combination with preexisting conditions. The Second Injury Fund was found to have no liability as the employee failed to meet the statutory requirements for permanent total disability benefits under Missouri law.
Polston v. State of Missouri, Fulton State Hospital(2021)
February 11, 2021#15-013956
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award denying workers' compensation to Tamara Polston for a March 10, 2015 left knee injury sustained when a psychiatric client kicked her. The ALJ found that employee failed to meet the requirements for Second Injury Fund compensation, as she was not permanently and totally disabled and her preexisting psychiatric condition did not aggravate the knee injury.
Merida v. AJM Packing Corporation(2021)
February 9, 2021#13-095197
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's October 29, 2019 award denying workers' compensation benefits in this case. The claimant Telma Merida's claim for injury no. 13-095197 sustained on August 1, 2013 was found to be unsupported by competent and substantial evidence.
Merida v. AJM Packing Corporation(2021)
February 9, 2021#12-040405
The Labor and Industrial Relations Commission affirmed the administrative law judge's award of compensation for employee Telma Merida. The decision was made on February 9, 2021, finding the ALJ's award was supported by competent and substantial evidence.
Austin v. AM Mechanical Services(2021)
February 3, 2021#11-112011
The Missouri Court of Appeals reversed the Commission's initial decision, and upon remand, the Commission affirmed that the employee's Kansas workers' compensation settlement validly barred him from pursuing a Missouri claim for the same March 10, 2011 workplace injury. The Commission found no fraud or duress in the Kansas settlement and upheld the employee's voluntary waiver of his right to pursue claims in other jurisdictions.
Lynch v. Anheuser Busch Companies, Inc.(2021)
February 2, 2021#09-03948509-101188
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's decision denying workers' compensation benefits to Mark Lynch for his January 15, 2009 occupational disease claim, finding no permanent and total disability despite the employee's carpal tunnel and tinnitus injuries. One commissioner dissented, arguing the evidence supported a finding of permanent and total disability based on the synergistic combination of the work-related occupational disease and pre-existing conditions, and that the Second Injury Fund should be liable.
Phelps v. Gideon 37 School District(2021)
January 25, 2021#16-025639
The Commission affirmed the Administrative Law Judge's denial of the employee's Second Injury Fund claim, finding that the employee failed to demonstrate a qualifying preexisting disability that combined with his primary left shoulder injury to result in permanent total disability. The Court rejected the employee's reliance on Parker, noting that subsequent appellate decisions specifically endorsed the Commission's denial methodology requiring consideration of only a single preexisting disability in combination with the primary injury.
Caldwell v. Unilever USA, Inc.(2021)
January 5, 2021#17-070606
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award finding that Carol Caldwell's left index finger injury sustained on August 20, 2017, was compensable under Missouri workers' compensation law. The award is temporary and partial, with the case remaining open for further proceedings regarding final compensation determinations.
Otwell v. Chrysler, LLC(2020)
December 30, 2020#09-015610
The Commission affirmed the Administrative Law Judge's award allowing workers' compensation for an employee's bilateral carpal tunnel syndrome work-related injury from February 10, 2009, with Second Injury Fund liability established due to synergistic effects with preexisting disabilities. The employee's primary disability was found to be 16% permanent partial disability referable to each wrist, with preexisting shoulder and incontinence disabilities resulting in a combined 33⅓% overall permanent partial disability and 32.52 weeks of additional liability against the Fund.
Barnes v. Karrenbrock Construction, Inc.(2020)
December 17, 2020#16-104170
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's decision denying workers' compensation benefits to Troy Barnes for bilateral carpal tunnel injuries sustained in November-December 2016. One commissioner dissented, arguing that the employee was permanently and totally disabled due to the combination of the carpal tunnel injuries and preexisting conditions, and should have been eligible for Second Injury Fund benefits.
Hinklin v. Stone Crest Motel(2020)
December 15, 2020#11-111607
The LIRC affirmed the administrative law judge's award of workers' compensation benefits to Cathy Hinklin for her November 17, 2011 work injury, finding the award supported by competent and substantial evidence. A dissenting opinion argued that the employee was already permanently and totally disabled before the primary injury and that surveillance evidence contradicted claims of physical and cognitive limitations.
McClain v. Birnamwood Condominium Association(2020)
December 15, 2020#15-064900
The LIRC affirmed the Administrative Law Judge's determination that Birnamwood Condominium Association was a statutory employer and that Meyers Trees & More, LLC was not properly insured under Missouri workers' compensation law. An employee of Meyers Trees was injured while performing tree-trimming work at the condominium complex after slipping off a roof.
Patrick v. Derek Mulvaney / Jerry Dierker Construction / City of Monett(2020)
December 3, 2020#16-056896
The Commission affirmed the Administrative Law Judge's award allowing workers' compensation benefits for Tommy Patrick's left hand injury sustained on March 17, 2016, while using a saw at work. The injury resulted in 25% permanent disability of the left hand and 6 weeks of disfigurement.
Owings v. McCray Lumber Company(2020)
December 2, 2020#19-008721
The Commission affirmed the Administrative Law Judge's award of workers' compensation to employee John Owings for a back and neck injury sustained when a 30-foot extension ladder fell and struck him on January 24, 2019. The claimant was awarded 10.5% permanent partial disability of the body as a whole totaling $20,847.96.
Joyner v. Monsanto(2020)
November 20, 2020#17-035903
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award finding the employer liable for the employee's permanent total disability. The decision was based on medical evidence showing physical restrictions that prevented the employee from successfully competing in the open labor market, despite a vocational expert's suggestions of available positions.
Beavers v. St. John's Mercy Medical Center(2020)
November 16, 2020#07-123519
The Labor and Industrial Relations Commission affirmed the administrative law judge's award allowing workers' compensation benefits for William Beavers' December 24, 2007 work injury. One commissioner dissented, arguing the ALJ erred in denying past medical benefits for post-surgery treatment and temporary total disability during the rehabilitative period.
Runyan v. Woodbridge Corporation(2020)
November 6, 2020#15-036868
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award allowing workers' compensation to employee Thomas Runyan for an alleged February 5, 2015 work injury involving chest pain sustained while operating a forklift. A dissenting opinion argued the employee failed to prove the work injury was the primary factor in his condition, noting his cardiac history and lack of subsequent musculoskeletal treatment.
Burns v. Associated Electric Cooperative, Inc.(2020)
October 27, 2020#17-091892
The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award of temporary or partial workers' compensation benefits for Edward Burns' left shoulder and neck injury sustained on November 29, 2017, when a lance slipped off a cart during repair work. The injury was found to be compensable under Missouri workers' compensation law, with medical expenses of $12,076.20 paid to date and the case kept open for further proceedings.
Knight v. FedEx Ground Package System, Incorporated(2020)
October 21, 2020#15-037031
The Missouri Labor and Industrial Relations Commission affirmed the administrative law judge's workers' compensation award for Bobby Knight, who sustained a compensable back injury while loading boxes on May 27, 2015. One dissenting member argued the employee should have been awarded greater permanent partial disability benefits based on medical evidence.