Supreme Court of Arkansas

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

February 27, 20142014 Ark. LEXIS 152

Summary

The court reversed the Commission’s denial of Prock’s workers’ compensation claim and remanded for a determination of benefits. Although the positive drug test triggered a presumption that marijuana substantially occasioned the accident, the Commission arbitrarily disregarded evidence rebutting that presumption and relied on speculation rather than substantial evidence of a direct causal link. The court declined to reach Prock’s constitutional challenges because the case could be resolved on the statutory issue. Justice Goodson, joined by Justice Baker, dissented, arguing that substantial evidence supported the Commission and that the majority improperly reweighed the facts.