Loar v. Cooper Tire & Rubber Co.
2014 Ark. App. 240
| Ark. Ct. App. | 2014Background
- James Loar, Jr., treated for chronic back pain from a 2005 compensable workplace injury, died of acute methadone intoxication on September 7, 2009.
- Between Sept. 3 and Sept. 7, 2009, Loar consumed 41 methadone pills although his prescription authorized six per day (24 total), i.e., 17 pills in excess.
- Medical and testimonial evidence showed Loar had an opioid addiction history predating the 2005 injury, had been double‑filling prescriptions (OxyContin), and obtained methadone from an unapproved physician because it was cheaper.
- Wife testified Loar was intoxicated, she hid his medications and asked him to stop methadone; Loar did not consume the excess pills as a suicide attempt.
- The Arkansas Workers’ Compensation Commission found the overdose was an unreasonable, nonwork‑related independent intervening cause of death and denied death benefits; beneficiaries appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Loar's methadone overdose was causally related to the 2005 compensable injury | Loar's beneficiaries: overdose arose from treatment for work injury and thus death is compensable | Employer: overdose was an independent, nonwork‑related intervening cause due to addiction and unreasonable conduct | Commission and court: overdose was an independent intervening cause, not causally related to the work injury; benefits denied |
| Whether the overdose was unreasonable conduct so as to break causal link | Beneficiaries: overdose can be reasonable response to pain; factual dispute over dosage and timing | Employer: excessive dosing, prior addiction, and conduct show unreasonableness | Held: overdose was unreasonable under the circumstances given addiction history, excessive use, and non‑acute pain indicators |
| Standard of review—whether evidence supports Commission's findings | Beneficiaries: evidence insufficient as a matter of law to support denial | Employer: substantial evidence supports Commission credibility determinations | Held: appellate court defers to Commission; substantial evidence supports the denial |
| Whether physician’s treatment was authorized (cross‑appeal) | Beneficiaries: challenge authorization of treatment | Employer: contested authorization | Held: Cross‑appeal rendered moot by primary ruling; not addressed |
Key Cases Cited
- Guidry v. J & R Eads Constr. Co., 11 A.3d 1180 (1984) (an intervening nonwork‑related cause arises where decedent’s unreasonable conduct breaks causal link)
- Wal‑Mart Stores, Inc. v. Sands, 91 S.W.3d 93 (2002) (standard of appellate review: view evidence in light most favorable to Commission)
- Olsten Kimberly Quality Care v. Pettey, 944 S.W.2d 524 (1997) (definition of substantial evidence)
- White v. Georgia‑Pacific Corp., 6 S.W.3d 98 (1999) (appellate court will not reverse Commission unless no fair‑minded persons could reach same conclusion)
- Farmers Coop. v. Biles, 69 S.W.3d 899 (2002) (Commission has sole province to assess witness credibility)
- Continental Express v. Harris, 965 S.W.2d 811 (1998) (Commission’s resolution of medical evidence has force of jury verdict)
- Eagle Safe Corp. v. Egan, 842 S.W.2d 438 (1992) (overdose may be compensable where overdose is not excessive, proximate to injury, and dosage unexplained)