Keith Bowdry v. City of Tupelo, Mississippi and Mississippi Municipal Workers' Comp Group, 2021-WC-00390-COA

Keith Bowdry, a Tupelo police officer, slipped pursuing a suspect on April 21, 2017; he sustained admitted injuries to his left hand/arm and back and received employer-covered treatment and surgeries for his left hand.
Bowdry had a history of three prior on-the-job neck/upper-back injuries (2011, 2013, 2015).
After the 2017 incident he sought treatment from Dr. Glenn Crosby for neck pain; the employer refused to authorize the treating physician and declined to pay for a cervical MRI by Dr. Crosby.
Bowdry amended his petition to add neck and right upper-extremity claims, sought continuances to obtain Dr. Crosby’s records and MRI review, but did not depose Dr. Crosby or produce admissible expert testimony at hearing.
The Administrative Judge denied benefits for the neck claim for lack of medical causation; the Mississippi Workers’ Compensation Commission affirmed, finding no competent expert or objective evidence linking the neck complaints to the April 21, 2017 injury.
On appeal the Court of Appeals reviewed the Commission’s decision under the substantial-evidence standard and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bowdry’s neck complaints are causally related to the April 21, 2017 work injury	Bowdry: neck pain diagnosed as cervical radiculopathy arose from the April 21, 2017 injury and employer should pay for treatment	Employer: neck complaints stem from prior injuries; Bowdry presented no competent expert evidence tying neck to 2017 injury	Held: Not related — affirmed (no competent medical causation shown)
Whether the Commission erred in finding lack of medical causation / failing to award benefits	Bowdry: Commission erred by denying benefits and by refusing to credit his medical records/testimony	Employer: Commission correct — claimant with prior neck injuries must prove causation with expert medical evidence; claimant failed to do so and did not introduce admissible records or expert testimony	Held: Commission did not err — substantial evidence supports finding claimant failed to meet burden to prove causation

Sheffield v. S.J. Louis Constr. Inc., 285 So. 3d 614 (Miss. 2019) (appellate review is of the Commission, not the administrative judge; Commission is factfinder)
Short v. Wilson Meat House LLC, 36 So. 3d 1247 (Miss. 2010) (same principle on scope of review)
Forrest Gen. Hosp. v. Humphrey, 136 So. 3d 468 (Miss. Ct. App. 2014) (appellate standard: substantial-evidence for factual findings; de novo for legal issues)
Burton v. Nissan N. Am., 305 So. 3d 1163 (Miss. Ct. App. 2020) (medical causation generally requires expert testimony except in simple cases)
Eichhorn v. Kroger Co., 325 So. 3d 692 (Miss. Ct. App. 2021) (where substantial credible evidence supports Commission, courts must affirm)