Farris v. Express Servs., Inc., 572 S.W.3d 863

Background

Farris sought additional workers' compensation benefits and filed an AR-C form on May 5, 2016, naming Great Dane as his employer.
The governing statute (Ark. Code Ann. § 11-9-702(b)(1)) bars additional-benefits claims filed later than one year after last payment or two years after the injury, whichever is greater. Two years from Farris's injury was May 12, 2016.
Farris corrected the AR-C on May 12, 2016 (dated) to name Express Services as his employer but the corrected form was filed on May 13, 2016 — one day after the two-year deadline.
The Arkansas Workers’ Compensation Commission found Farris’s claim time-barred; the Court of Appeals had reached a contrary result, prompting Supreme Court review.
The Supreme Court majority held the corrected filing was untimely and affirmed the Commission; Justice Hart dissented, arguing the amendment should relate back and Dillard controls.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Farris timely filed an additional-benefits claim under Ark. Code Ann. § 11-9-702(b)(1)	Farris: the May 5 AR-C tolled the statute despite naming the wrong employer; the filing was timely and the May 13 correction relates back	Commission/Appellees: the May 13 corrected form was filed after the two-year limit and the May 5 form sought benefits against the wrong employer, so the claim is barred	Held: Claim barred. The majority concluded the May 13 correction was one day late; the Commission's time-bar finding is supported by substantial evidence
Whether a mistaken identification of the employer on an AR-C is excused under Dillard	Farris: Dillard permits relief where a timely form contains a technical mistake; substance over form should apply	Appellees: distinction from Dillard because Farris filed two distinct forms and sought benefits against the wrong employer on the initial filing	Held: Majority distinguished Dillard and declined to apply it; Dillard found inapplicable to this factual posture
Whether the amendment relates back to the original filing date	Farris: the relation-back doctrine applies (four-factor test from Southwestern Bell/Harvill); Appellees had notice and would not be prejudiced	Appellees: asserted that the correction was untimely and did not cure the statute-of-limitations issue	Held: Majority rejected relation-back as to timeliness here and affirmed statute-of-limitations bar; dissent argued relation back applied
Standard of review for Commission findings and statutory construction	Farris: urged de novo statutory construction and that evidence supports tolling	Appellees: emphasized appellate deference to Commission and statutory plain language requiring strict deadlines	Held: Court applied substantial-evidence review to Commission factual findings and de novo review to statutory interpretation; affirmed Commission under substantial-evidence standard

Key Cases Cited

Crudup v. Regal Ware, Inc., 341 Ark. 804, 20 S.W.3d 900 (evidentiary standard for Commission decisions)
Wallace v. W. Fraser South, Inc., 365 Ark. 68, 225 S.W.3d 361 (deference to Commission when supported by substantial evidence)
Johnson v. Bonds Fertilizer, Inc., 365 Ark. 133, 226 S.W.3d 753 (rules for statutory construction)
Stewart v. Ark. Glass Container, 2010 Ark. 198, 366 S.W.3d 358 (claimant must prove timely filing for additional compensation)
Houston Contracting Co. v. Young, 267 Ark. 322, 590 S.W.2d 653 (statute-of-limitations is largely a question of fact)
Southwestern Bell Tel. Co. v. Blastech, Inc., 313 Ark. 202, 852 S.W.2d 813 (four-factor relation-back test for amendments changing identity of party)
Harvill v. Cmty. Methodist Hosp. Ass'n, 302 Ark. 39, 786 S.W.2d 577 (relation-back principles)
Dillard v. Benton Cty. Sheriff's Office, 87 Ark. App. 379, 192 S.W.3d 287 (mistaken entries on AR-C should not time-bar a timely additional-benefits filing)
Plante v. Tyson Foods, Inc., 319 Ark. 126, 890 S.W.2d 253 (date of last payment construed as last furnishing of medical services)