Grantham v. Hornbeck Agricultural Group, LLC, 2017 Ark. App. 520

Randy Grantham, a Hornbeck Agricultural salaried manager since 2011, testified he felt a pop in his lower back on October 16, 2013, while setting an auger at work and thereafter experienced left-leg numbness and weakness (drop foot).
He sought treatment the next day from his primary physician, Dr. Burleson, and obtained an MRI showing multilevel degenerative disc disease and foraminal stenosis most significant at L4-5.
Specialist Dr. Scott Schlesinger diagnosed lumbar stenosis and degenerative disc disease, recommended injections and PT, and stated (with equivocation) that the injury ‘‘seems to have caused the onset of symptoms’’ though the accident “did not or may or may not have caused the actual radiological findings.”
Grantham underwent three back surgeries in 2014, continued as a salaried employee until Hornbeck closed in February 2015, paid earlier treatment through employer-provided health insurance, and filed a workers’ compensation claim on July 13, 2015.
The ALJ denied benefits, finding Grantham failed to prove a compensable traumatic injury or an aggravation of a preexisting condition supported by objective findings; the Commission adopted and affirmed that decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Grantham proved a compensable, specific-incident work injury producing objective medical findings	Grantham argued his October 16, 2013 lifting incident caused onset/worsening of back symptoms and produced objective findings (MRI, exams) and disability	Hornbeck argued Grantham’s condition was preexisting degenerative disease, the medical evidence is equivocal on causation, and treatment related to degeneration is not a compensable traumatic injury	Commission affirmed ALJ: Grantham failed to prove compensable injury with objective findings or that a specific traumatic event aggravated a preexisting condition

Ganus v. St. Bernard’s Hosp., LLC, 457 S.W.3d 683 (Ark. Ct. App. 2015) (standard for reviewing Commission findings and viewing evidence favorably to Commission)
Willis v. Great Dane Trailers, 444 S.W.3d 423 (Ark. Ct. App. 2014) (substantial-evidence standard when claimant fails to meet burden)
Cedar Chem. Co. v. Knight, 273 S.W.3d 473 (Ark. 2008) (credibility and weight of witness testimony are Commission’s province)
Mack-Reynolds Appraisal Co. v. Morton, 375 S.W.3d 6 (Ark. Ct. App. 2010) (appellate court bound by Commission credibility determinations)
Crudup v. Regal Ware, Inc., 20 S.W.3d 900 (Ark. 2000) (insufficient medical causation where physician language is equivocal)
Frances v. Gaylord Container Corp., 20 S.W.3d 280 (Ark. 2000) (same principle regarding medical causation language)