Supreme Court of Arkansas

Matthew L. Edmisten, Appellee v. Bull Shoals Landing and Aig Domestic Claims, Inc., Appellees

February 27, 20142014 Ark. LEXIS 147

Summary

The court reversed the Commission’s denial of workers’ compensation benefits and remanded for a determination of benefits. Although Edmisten’s positive marijuana test triggered a statutory presumption that the accident was substantially occasioned by illegal-drug use, the Commission arbitrarily disregarded supporting testimony and relied on speculation rather than substantial evidence of a direct causal link. The court did not reach Edmisten’s constitutional challenge to the Commission’s structure. Justices Baker and Goodson dissented, concluding that the Commission’s decision was supported by substantial evidence and that the majority misconstrued the statutory presumption.