Mineral Springs School District and Arkansas School Boards Association v. Margaret MacOn
2025 Ark. App. 48
| Ark. Ct. App. | 2025Background
- Margaret Macon, a 68-year-old math teacher, fell when a desk collapsed at her workplace in October 2020.
- She did not immediately seek medical attention, but her pain worsened over several days, leading her to seek treatment for back and neck pain.
- Medical imaging revealed existing degenerative changes but also new and more severe findings at certain spinal levels.
- Macon had prior neck issues from car accidents in 2016 and 2017, but testified she had been asymptomatic for nearly three years before this incident.
- The Arkansas Workers’ Compensation Commission found Macon's injuries compensable and her subsequent medical treatment reasonably necessary, despite her history of preexisting conditions.
- The School District and its insurer appealed, arguing her injuries were not compensable due to preexisting conditions and lack of acute objective findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Compensability of back injury | Work fall caused new back injury; objective findings (spasm) present | Symptoms minor; x-rays normal; no acute findings | Injury compensable; credible, objective findings support claim |
| Compensability of neck injury | Work incident aggravated or caused new neck trauma; more severe findings than prior | Prior accidents caused current neck issues; no new objective findings | New trauma at C6-7, new severity; injury compensable |
| Necessity of medical treatment | All treatment related to compensable injuries | Treatment not related to work injury | All treatment, including proposed surgery, compensable |
| Preexisting condition effect | Asymptomatic before work fall; aggravation is compensable | Preexisting conditions disqualify compensation | Aggravations of preexisting conditions are compensable |
Key Cases Cited
- Patterson v. Ark. Dep’t of Health, 343 Ark. 255 (questions of credibility are for the Commission)
- Weaver v. Nabors Drilling USA, 98 Ark. App. 161 (substantial evidence standard of review for Commission decisions)
- Vaughn v. Midland Sch. Dist., 2012 Ark. App. 344 (aggravations of preexisting conditions are compensable if work-related)
- Arbaugh v. AG Processing, Inc., 360 Ark. 491 (reviewing court foreclosed from assessing witness credibility)
- Poulan Weed Eater v. Marshall, 79 Ark. App. 129 (Commission can accept or reject medical opinions)