All Missouri workers' compensation decisions

The Commission affirmed the administrative law judge's award allowing workers' compensation benefits for the death of Tyler Halsey, finding that his heat stroke and fatal collapse while working as a tree laborer in extreme heat constituted a compensable injury arising out of and in the course of his employment. The Commission rejected the employer's affirmative defense that the injury resulted from idiopathic causes (obesity), finding that the unexpected traumatic event of working in extremely hot weather was the prevailing factor in causing the heat stroke and death.

The Missouri LIRC affirmed the administrative law judge's award of workers' compensation benefits to Angelina Summers, including future medical benefits and approval of attorney's fees. A dissenting opinion argues the disability level should be modified, contending the employee failed to prove permanent total disability based on objective medical findings and vocational rehabilitation evidence.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award allowing workers' compensation benefits for an employee's tinnitus claim related to noise exposure. A dissenting opinion argued the employee failed to establish medical causation between work-related noise exposure and tinnitus, as the underlying hearing loss was deemed non-compensable.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award denying workers' compensation benefits to Steven A. Shipley for claimed psychiatric stress and mental/cerebral hemorrhage allegedly caused by supervisor harassment. The employee failed to meet the burden of proving that work-related stress rose to the level of extraordinary and unusual stress required under Missouri law.

The LIRC affirmed the administrative law judge's denial of workers' compensation benefits, finding that the employee failed to prove her shoulder and hand conditions (rotator cuff tendinitis, impingement syndrome, and arthritis) were causally related to her work activities. Dr. Strege's credible expert medical opinion established that the employee's job activities were not the prevailing factor causing her conditions, and she had reached maximum medical treatment.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award allowing workers' compensation benefits to the surviving dependents of Michel Ziade, finding that Quality Business Solutions, Inc. failed to prove it had terminated its co-employer agreement with First Class Medical Transportation prior to the employee's fatal work-related accident on July 28, 2015. The Commission also determined that issues of judicial and collateral estoppel raised by QBS were outside the scope of the administrative agency's jurisdiction.

The Labor and Industrial Relations Commission affirmed the administrative law judge's Final Award on Medical Fee Dispute, finding that the health care provider's application for payment of additional reimbursement was not timely filed as required by § 287.140.4. The Commission preserved constitutional arguments raised by the health care provider for potential appeal but did not address them as outside their jurisdiction.

The Missouri LIRC reversed the Administrative Law Judge's award of permanent total disability benefits against the Second Injury Fund, finding that the ALJ misapplied statutory criteria by improperly including preexisting conditions in the analysis. The employee, an aircraft simulation technician, claimed permanent total disability based on left carpal tunnel syndrome combined with preexisting conditions including right shoulder degenerative changes and left knee issues, but the Commission determined the Second Injury Fund was not liable.

The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's temporary award granting Georgetta Hull workers' compensation benefits and future medical treatment for a right shoulder injury sustained in a July 2, 2018 work accident. The majority found the award was supported by competent and substantial evidence, though a dissenting opinion argued the employee failed to prove medical causation between the work accident and the shoulder condition.

The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award of workers' compensation benefits for Benjamin Branch's low back injury sustained on November 13, 2017, finding 14.5% permanent partial disability. A dissenting opinion disputed the disability percentage, arguing the evidence supported only 5% permanent partial disability rather than 14.5%.

The Missouri Court of Appeals reversed the Commission's denial of permanent total disability benefits, and the Commission on remand awarded the Second Injury Fund liable for permanent total disability benefits beginning May 3, 2013, at differential and then stipulated weekly rates continuing for the employee's lifetime. The injury resulted from a hanging toolbox striking the claimant on the head and left shoulder on June 15, 2012, while employed at General Motors LLC in St. Charles County.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award denying permanent total disability compensation to Judith Gustin for a November 27, 2014, trip and fall injury at work. The Commission found that objective medical evidence from independent orthopedic physicians (MRI imaging and physical examinations) supported the conclusion that the injury resulted only in a contusion without permanent structural damage or disability.

The Missouri LIRC affirmed the administrative law judge's denial of workers' compensation benefits, finding the employee failed to prove she sustained an accident arising out of and in the course of her employment. The employee's claim alleged steam exposure at a restaurant caused throat and speech problems, but the court found her testimony not credible and the causal connection to a work accident insufficient.

The Missouri LIRC affirmed the Administrative Law Judge's final award denying all workers' compensation benefits to Janet K. Scott for a left ankle injury sustained on March 16, 2010, while inspecting parts at her workplace. Although the injury was found to be work-related and compensable under Missouri law, no benefits were awarded because the claim was not filed within the time required by law.

The Commission affirmed the Administrative Law Judge's decision denying all workers' compensation benefits, finding that although the injury to the left shoulder occurred in the course of employment on July 15, 2009, the claim was filed outside the time required by law. No compensation was awarded to the employee Janet K. Scott.

The Labor and Industrial Relations Commission modified the Administrative Law Judge's award in a workers' compensation case involving William Haynes, who sustained work-related injuries including facial lacerations, nasal and orbital fractures, concussion, and L3 compression fracture on April 22, 2015. The Commission adjusted the award and decision while adopting the ALJ's findings to the extent they were not inconsistent with the modifications, addressing issues of compensability, wage rates, medical causation, and permanent partial disability ratings.

The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award regarding liability in this workers' compensation case involving an inventory clerk with bilateral carpal syndrome. The case is marked as a temporary or partial award with proceedings remaining open for final determination.

The Commission modified the administrative law judge's award regarding a work-related occupational disease (L4-5 disc herniation) sustained by Jeffrey Dudley while employed at Chrysler LLC on July 10, 2008. The decision addressed the prevailing factor causing the injury, employer's liability for past medical expenses, and the Second Injury Fund's liability.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award of workers' compensation benefits for Jackie W. Hooper's work-related knee injuries involving two tears to the medical meniscus. The commission found the award was supported by competent and substantial evidence and in accordance with Missouri Workers' Compensation Law, though one member filed a dissenting opinion regarding the scope of future medical treatment responsibility.

The Commission reversed the administrative law judge's decision and found the Second Injury Fund (SIF) liable for compensation in this case involving a preexisting condition of osteogenesis imperfecta. The employee sustained a compensable right knee injury on September 1, 2010, and the Commission determined that the preexisting condition constituted a hindrance or obstacle to employment for purposes of SIF liability.

The Commission reversed the administrative law judge's award granting Second Injury Fund liability for permanent total disability benefits. The decision focused on whether employee's preexisting conditions (head injury from 1981 and knee surgery from 1982) met the criteria for Second Injury Fund coverage under Missouri law.

The Commission affirmed the Administrative Law Judge's denial of workers' compensation benefits for a recurrent disc herniation at L5-S1, finding that the employee failed to establish work duties as the prevailing factor in causing the injury. The court found Dr. Coyle's medical opinions unpersuasive, noting his 2017 deposition testimony contradicted his earlier written opinions regarding causation.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award of workers' compensation for Jackie W. Hooper's work-related knee injuries (medial meniscus tears) sustained at the Missouri Department of Corrections. One dissenting opinion argued that future medical treatment should be limited to care directly addressing the compensable injury rather than all conditions affecting the injured body part.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award denying workers' compensation benefits to the estate of Lula Gray for an alleged left shoulder injury. The Commission found that while the employee was in the course of employment, the injury was not compensable under Missouri workers' compensation law, and no benefits were awarded.

The Commission affirmed the Administrative Law Judge's award denying permanent total disability compensation to Sterling Bennett for his March 24, 2014 work injury, finding that his permanent partial disability (25% left hand, 5% body as a whole for ribs) did not meet the statutory requirements for Second Injury Fund liability. The expert opinions presented failed to establish that the combination of the primary injury and preexisting disabilities resulted in permanent total disability as required by Missouri law.