Godwin v. Garland County Landfill
2016 Ark. App. 498
| Ark. Ct. App. | 2016Background
- Shannon Godwin filed a workers’ compensation claim alleging a left-knee injury on March 17, 2014 after slipping off a truck step while collecting his belongings following termination. Employer controverted the claim.
- Godwin waited ~5–6 weeks before seeking medical treatment (April 29) and underwent three arthroscopic knee surgeries in 2014; he also had a prior compensable neck/shoulder injury from 2012.
- At the administrative hearing Godwin gave inconsistent dates (initially February 17), admitted delay in reporting, and acknowledged prior disciplinary write-ups and recent termination at the same time as the alleged event.
- Employer witnesses (supervisor and fleet manager) testified they did not observe the incident, were unaware of any injury at the time, and first learned of the injury months later.
- The ALJ found Godwin not credible and concluded that causal connection between employment and his knee condition would require speculation; the Commission (2–1) affirmed the ALJ. The Court of Appeals reviewed for substantial evidence and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Godwin proved a compensable specific-incident knee injury arising out of/in course of employment | Godwin: medical history matches his account; there is objective injury and no alternative cause offered, so Commission must accept his version | Garland: Commission alone determines credibility; without credible testimony causal link would be speculative and cannot be supplied | Affirmed: Commission’s credibility finding and decision that causation would require speculation supported by substantial evidence |
Key Cases Cited
- SSI, Inc. v. Cates, 350 S.W.3d 421 (Ark. App. 2009) (Commission may adopt ALJ opinion, making it the Commission’s findings)
- Martin Charcoal, Inc. v. Britt, 284 S.W.3d 91 (Ark. App. 2008) (Commission resolves credibility and medical conflicts)
- Parker v. Atl. Research Corp., 189 S.W.3d 449 (Ark. App. 2004) (standard for reviewing Commission decisions; substantial-evidence test)
- Parker v. Comcast Cable Corp., 269 S.W.3d 391 (Ark. App. 2007) (appellate review defers to Commission if supported by substantial evidence)
- Ark. Dep’t of Correction v. Glover, 812 S.W.2d 692 (Ark. App. 1991) (speculation cannot supply causal connection for compensability)