Knight v. Public Employees' Retirement System
108 So. 3d 912
| Miss. | 2012Background
- Knight, a Mississippi State Senate committee assistant, sought non-duty-related disability benefits from PERS after years of foot pain and related symptoms.
- PERS Medical Board found insufficient evidence of permanent disability; the Disability Appeals Committee and Board denied benefits.
- Knight testified to chronic foot pain, balance issues, and inability to walk long distances; she had multiple foot surgeries and various diagnoses.
- She resigned from her job in 2006 and pursued disability benefits, submitting medical history and physician evaluations over several years.
- The circuit court and Court of Appeals upheld the PERS denial; the Supreme Court granted certiorari and reversed.
- The majority concluded Knight’s record contained substantial evidence supporting disability under Mississippi law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PERS’s denial was supported by substantial evidence | Knight contends the record shows permanent impairment and mobility limits. | Knight failed to provide objective medical evidence of disability. | Knight’s disability established; PERS decision reversed and rendered. |
| Whether Laughlin governs the Court of Appeals’ reliance | Knight argues Laughlin is distinguishable and misapplied. | PERS and Court of Appeals relied on Laughlin appropriately. | Laughlin properly distinguished; not controlling against Knight. |
| Whether Knight met the statutory definition of disability under §25-11-113(l)(a) | Knight satisfied incapacity and permanency through medical evidence and impairments. | Medical evidence insufficient to prove permanent disability. | Knight proved disability under statute; Court should reverse and render. |
Key Cases Cited
- Pub. Employees’ Ret. Sys. v. Marquez, 774 So.2d 421 (Miss. 2000) (defining substantial evidence and deference to PERS)
- Pub. Employees’ Ret. Sys. v. Dishmon, 797 So.2d 888 (Miss. 2001) (substantial-evidence standard; defer to agency findings)
- Dearman v. Pub. Employees’ Ret. Sys., 846 So.2d 1014 (Miss. 2003) (pain as disability evidenced by medical proof)
- Pub. Employees’ Ret. Sys. v. Waid, 823 So.2d 595 (Miss. Ct. App. 2002) (pain and disability considerations in PERS decisions)
- Laughlin v. Pub. Employees’ Retirement Sys., 11 So.3d 154 (Miss. Ct. App. 2009) (physician opinions; dispositive findings discussed)
- Stevison v. Pub. Employees’ Ret. Sys., 966 So.2d 874 (Miss. Ct. App. 2007) (reweighing not allowed; substantial evidence required)
- Howard v. Pub. Employees’ Ret. Sys., 905 So.2d 1279 (Miss. 2005) (burden on claimant to prove disability)
- Pub. Employees’ Ret. Sys. v. Dearman, (referenced in opinion) (Miss.) (example of overturning if lack of substantial evidence)