Ex parte Professional Business Owners Association Workers' Compensation Fund and Piknik Products Company, Inc. (In re Samson Addy, surviving dependent spouse of Annie Addy, et al. v. Professional Business Owners Association Workers' Compensation Fund and Piknik Products Company, Inc.)

Summary

The Supreme Court of Alabama held that the Court of Civil Appeals improperly considered evidence that the trial court had treated as inadmissible hearsay and that the respondent had not challenged on appeal. The court reversed and remanded with directions to affirm the trial court's judgment that Annie Addy's death was not compensable under the Alabama Workers' Compensation Act. A dissent argued that the ore tenus standard did not apply to stipulated facts and written evidentiary materials and that the majority inferred too much from the trial court's order.

Holdings

1. The Court of Civil Appeals erred by considering and relying on testimony that the trial court had excluded from its findings as inadmissible hearsay and that Samson Addy had not challenged on appeal.
2. The trial court's findings of fact could not be reversed if supported by substantial evidence, and the appellate court was required to view the facts in the light most favorable to those findings.

Questions Presented

1. Whether the Court of Civil Appeals improperly considered and relied on evidence that the trial court had determined was inadmissible and that the appellee had not challenged as error on appeal.
2. Whether the Court of Civil Appeals was required to review the trial court's workers' compensation findings in the light most favorable to those findings and defer to findings supported by substantial evidence.

Disposition

reversed_and_remanded