J.B. Hunt Transport Services Inc. v. Hollingsworth, 2016 Ark. App. 279

On July 14, 2014, Gregory Hollingsworth, a long‑time truck driver employed by J.B. Hunt, was injured in a work‑related rollover; J.B. Hunt accepted the claim as compensable but disputed additional treatment and TTD benefits.
Immediate ER imaging showed chronic degenerative cervical changes; Hollingsworth testified he had no prior neck complaints, treatment, or imaging before the accident.
Treated first by Dr. Rebecca Lewis (DO), who noted cervical spasms, an "inappropriate pain response" on light touch, and ordered an MRI; MRI was read as showing chronic degenerative changes only.
Neurosurgeon Dr. Luke Knox evaluated Hollingsworth, recommended further testing (myelogram), diagnosed extrinsic nerve‑root compression based on his exam and myelogram, and recommended cervical discectomy and fusion.
The ALJ and the full Arkansas Workers’ Compensation Commission (2–1) awarded additional medical treatment (surgery) and temporary total disability (TTD) from October 21, 2014, onward; J.B. Hunt appealed asserting lack of substantial evidence of causation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether additional medical treatment (neck surgery) is causally related to the July 14, 2014 work injury	Hollingsworth: treating neurosurgeon (Dr. Knox) opines, to reasonable medical certainty, injury caused/exacerbated by the wreck; objective support in myelogram, positive Spurling, exam and consistent complaints	J.B. Hunt: preexisting chronic degenerative cervical disease shown on ER CT/MRI and Dr. Lewis’s notes; myelogram and imaging show chronic, not acute, changes—insufficient causation	Commission affirmed: substantial evidence supports causation and entitlement to surgery (crediting Dr. Knox and objective findings)
Whether Hollingsworth is entitled to temporary‑total‑disability (TTD) benefits while awaiting treatment/recovery	Hollingsworth: Dr. Knox unrebutted opinion that time off is appropriate while delineating injury/treatment; he cannot perform driving work	J.B. Hunt: argues preexisting condition and lack of objective acute injury undermine need for TTD	Commission affirmed: substantial evidence supports TTD from Oct. 21, 2014, pending treatment/recovery

Express Human Res. III v. Terry, 61 Ark. App. 258, 968 S.W.2d 630 (1998) (standard for affirming Commission when supported by substantial evidence)
Leach v. Cooper Tire & Rubber Co., 2011 Ark. App. 571 (appellate review views evidence in light most favorable to Commission)
Hargis Transp. v. Chesser, 87 Ark. App. 301, 190 S.W.3d 309 (2004) (deference to Commission on credibility and conflict resolution)
Oak Grove Lumber Co. v. Highfill, 62 Ark. App. 42, 968 S.W.2d 637 (1998) (Commission may accept/reject medical opinion)
Pack v. Little Rock Convention Ctr., 2013 Ark. 186, 427 S.W.3d 586 (credibility and weight of testimony are for Commission)
Ozark Nat. Food v. Pierson, 2012 Ark. App. 133, 389 S.W.3d 105 (consideration of ALJ opinion when adopted by Commission)
Maxwell v. Carl Bierbaum, Inc., 48 Ark. App. 159, 893 S.W.2d 346 (1995) (claimant's burden to prove compensability by preponderance)
Cont'l Exp., Inc. v. Freeman, 339 Ark. 142, 4 S.W.3d 124 (1999) (muscle spasms are objective findings)
St. Edward Mercy Med. Ctr. v. Chrisman, 2012 Ark. App. 475, 422 S.W.3d 171 (Commission's resolution of medical evidence has jury‑verdict force)
Poulan Weed Eater v. Marshall, 79 Ark. App. 129, 84 S.W.3d 878 (2002) (deference to Commission on medical testimony)
Arbaugh v. AG Processing, Inc., 360 Ark. 491, 202 S.W.3d 519 (2005) (Commission determines credibility and weight)