Greg E. Prock, Appellant v. Bull Shoals Boat Landing & American Home Assurance/aig Claim Services, Inc., Appellees

Summary

The court reversed the Workers’ Compensation Commission’s denial of benefits and remanded for a determination of benefits, holding that the Commission arbitrarily disregarded evidence rebutting the statutory presumption arising from Prock’s positive drug test. The court concluded that the record did not contain substantial evidence of a direct causal link between marijuana use and the accident, which instead resulted from Prock’s unsafe use of an acetylene torch to open a barrel. The court declined to decide Prock’s constitutional and due-process challenges because the case could be resolved on the statutory and evidentiary grounds. Justice Goodson, joined by Justice Baker, dissented, arguing that the Commission’s decision was supported by substantial evidence and that the majority improperly reweighed the evidence.