Robbins v. Hilark Industries, Inc., 2017 Ark. App. 431

Corey Robbins, a painter at HilArk Industries, suffered sudden cardiac arrest at home on July 6, 2015, after working in a high, ventilated paint booth earlier that day. He was resuscitated and hospitalized.
At work Robbins became overheated, went to the break room to cool off, rehydrated, and repeatedly told supervisors he felt fine and intended to finish the day.
That evening Robbins became unwell at home, then went into cardiac arrest; his fiancée witnessed the collapse. Hospital testing showed a negative drug screen; he was later diagnosed with takotsubo cardiomyopathy by one treating cardiologist.
Robbins had significant nonwork-related risk factors: congenital chest abnormality (pectus excavatum), history of drug abuse, recent depression and stressors, and ongoing personal financial and family stress.
Robbins filed a workers’ compensation claim asserting the cardiac arrest was caused by workplace heat exposure, dehydration, and chemical exposure; the ALJ and the Arkansas Workers’ Compensation Commission found he failed to prove a compensable injury.
The Commission discounted Dr. Hutchins’s opinion that the event was "more likely than not" work-related, concluding his opinion relied on incomplete/inaccurate history; the Commission found other medical evidence and facts supported nonwork causes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Robbins proved a compensable cardiovascular injury under Ark. Code § 11-9-114 (accident must be the major cause)	Robbins: heat exhaustion, dehydration, and workplace conditions were the precipitating accident causing cardiac arrest	Employers: Robbins cooled down, rehydrated, had nonwork-related risk factors and medical history; causation not established	Commission and appellate court: Held Robbins failed to prove compensable injury; substantial evidence supports denial
Whether medical testimony supported causation	Robbins: Dr. Hutchins opined it was "more likely than not" work-related	Employers: Other cardiologists did not agree; Hutchins relied on inaccurate history	Court: Rejected Hutchins’s opinion as based on incomplete/inaccurate history; credibility determination for Commission
Whether substantial evidence standard met on appeal	Robbins: Commission’s decision unsupported by substantial evidence	Employers: Commission resolved conflicting evidence reasonably	Court: Affirmed — reasonable minds could reach Commission’s conclusion
Whether extraordinary/unusual exertion requirement satisfied	Robbins: work conditions were extraordinary that day	Employers: Activities were within ordinary duties and Robbins stopped work to cool off	Court: Did not reach second statutory prong because Robbins failed first prong (accident as major cause)

Schall v. Univ. of Ark. for Med. Scis., 510 S.W.3d 302 (Ark. App. 2017) (articulates appellate review and deference to Commission on credibility and conflicting medical evidence)
Ayers Drywall & Insulation v. Carey, 352 S.W.3d 334 (Ark. App. 2009) (conflicting medical evidence resolution by Commission is binding when supported by substantial evidence)