Rural Waste Management & Indemnity Insurance Co. of North America v. Mock

Summary

The Oklahoma Supreme Court reviewed a workers' compensation award involving an employee's cumulative hip, back, and leg injuries and a subsequent motor-vehicle accident. The court held that the any competent evidence standard applied and that competent medical evidence supported the finding that employment was the major cause of the injury. The court vacated the Court of Civil Appeals' decision and sustained the Workers' Compensation Court's award.

Holdings

1. The any competent evidence test, rather than the clear-weight-of-the-evidence standard, applies to appellate review of this workers' compensation claim.
2. Mock established by competent medical evidence that his employment was the major cause of his personal injury arising out of and in the course of employment; the injury was therefore compensable under the Workers' Compensation Code.

Questions Presented

1. What standard of appellate review applies to a workers' compensation claim filed in 2009?
2. Whether competent evidence supported the finding that Mock's employment was the major cause of his compensable injury.

Disposition

vacated