Arnold v. Toyota Motor Manufacturing
2012 Ky. LEXIS 122
| Ky. | 2012Background
- Claimant suffered a work-related right shoulder injury after transferring to the assembly line in April 2007.
- ALJ awarded temporary total disability (TTD) from May 10, 2007 to May 8, 2009, plus permanent and medical benefits; denied cervical/lumbar claims.
- Board found substantial evidence claimant left work on May 15, 2007 due to a work-related condition.
- Court of Appeals majority reversed, remanding for clearer findings on the TTD start date.
- Supreme Court reversed in part, affirming the TTD award's basis but remanding to clarify evidentiary support for the May 10, 2007 start date.
- Medical proof showed MMI reached May 8, 2009; surgery occurred November 2008; claimant stopped work May 15, 2007 per testimony, but May 10, 2007 is the date contested.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ properly establish the TTD start date? | Arnold's May 15, 2007 cessation supports May 15 start. | TTD began no earlier than May 10, 2007 or later based on evidence. | Remanded to clarify May 10, 2007 start date; cannot determine basis from record. |
| Was the evidentiary basis for the May 10, 2007 date adequately stated? | ALJ provided extensive evidence supporting May 10, 2007 as the start. | The opinion failed to state evidentiary basis tying May 10, 2007 to impairment preventing work. | Reversed-in-part to require clarification of the evidentiary basis for May 10, 2007. |
| Does the Board have authority to review findings of fact in this context? | ALJ’s detailed findings support TTD and MMI timelines. | Board cannot reweigh evidence; must defer to ALJ’s findings. | Affirmed remand for clarification; Court retains authority to ensure proper findings and substantial evidence support. |
Key Cases Cited
- Central Kentucky Steel v. Wise, 19 S.W.3d 657 (Ky. 2000) (TTD principles and evidence sufficiency in Kentucky workers’ compensation)
- Magellan Behavioral Health v. Helms, 140 S.W.3d 579 (Ky. App. 2004) (appellate review of medical-evidence findings in compensation cases)
- Beech Creek Coal Co. v. Cox, 314 Ky. 743, 744, 237 S.W.2d 56, 57 (Ky. 1951) (entitlement to findings of fact and conclusions of law)
- Hush v. Abrams, 584 S.W.2d 48 (Ky. 1979) (review standards for workers’ compensation decisions)
- Carte v. Loretto Motherhouse Infirmary, 19 S.W.3d 122 (Ky. App. 2000) (evidentiary basis required for findings of fact)
- Vessels v. Brown-Forman Distillers Corporation, 793 S.W.2d 795 (Ky. 1990) (foundation for sufficiency of evidence in findings)
- Kentland Elkhorn Coal Corporation v. Yates, 743 S.W.2d 47 (Ky. App. 1988) (need for evidentiary basis in findings of fact)
- Shields v. Pittsburg and Midway Coal Mining Company, 634 S.W.2d 440 (Ky. App. 1982) (evidentiary support relevant to findings on appeal)
- Special Fund v. Francis, 708 S.W.2d 641 (Ky. 1986) (ornamental discussion of evidentiary requirements in findings)