Paula Russell v. Wal-Mart Stores, Inc.

Summary

The South Carolina Supreme Court held that the Workers' Compensation Commission’s Appellate Panel erred in finding Paula Russell had not proven a change of condition, because the panel’s decision was not supported by substantial evidence. Accordingly, the Court reversed the panel’s denial and remanded with instructions to award the additional benefits Russell sought. The decision rests on the statutory requirement that a claimant prove a change of condition by a preponderance of the evidence and on the proper application of the substantial‑evidence standard of review.