Curtis v. Lemna

Summary

The court held that the Arkansas Workers’ Compensation Commission had exclusive original jurisdiction to determine whether Arkansas workers’ compensation law applied and whether the co-employee was entitled to immunity. It further held that substantial evidence supported findings that the golf outing occurred within the scope of employment and that the co-employee was acting as an extension of the employer while driving the golf cart, making him immune from the tort action. The court did not reach the merits of the constitutional challenge because controlling precedent had already resolved that issue.