Robert March v. Treasurer of the State of Missouri - Custodian of the Second Injury Fund

Summary

The Supreme Court of Missouri affirmed the Labor and Industrial Relations Commission’s denial of permanent total disability benefits to Robert March, holding that he failed to meet his burden of persuasion that his pre‑existing disabilities combined with his work‑related injuries rendered him permanently and totally disabled. The Court explained that the claimant must prove by a preponderance of the evidence that the combination, not the pre‑existing condition alone, caused the disability, and that the commission is not required to give the Fund a benefit of the doubt when the claimant’s evidence is unimpeached.