Bobby Stewart v. Arkansas Glass Container and Risk Management Resources

Summary

The court held that Stewart’s claim for additional workers’ compensation benefits was untimely because it was filed more than one year after his last compensation payment and more than two years after his injury. His earlier request for additional medical benefits did not toll the limitations period for other benefits because that request was adjudicated and did not identify or preserve separate claims. Justice Sheffield, joined by the Chief Justice and Justice Corbin, dissented, concluding that the later filing sought modification of an earlier physician-change order and should not have been barred.