PEOPLELINK, LLC. v. BEAR

Summary

The Oklahoma Supreme Court held that the clear-weight-of-the-evidence standard in effect when the claimant was injured governed appellate review of the workers’ compensation award. The court rejected the Court of Civil Appeals’ use of the any-competent-evidence standard, vacated its opinion, and remanded for review under the clear-weight standard. The court also held that a party seeking review must specifically identify the evidence allegedly misweighed and explain why the ruling is against the clear weight of the evidence.

Holdings

1. The against-the-clear-weight-of-the-evidence standard in 85 O.S. Supp. 2010, § 3.6 applied to all injuries occurring during that statute's effective period, including Bear's March 4, 2011 injury.
2. Reviewing appellate courts must show the same deference to the Workers' Compensation Court's weighing of evidence that appellate courts show to a trial court deciding a case of equitable cognizance.
3. A party seeking appellate review under the clear-weight-of-the-evidence standard must state with specificity why the challenged ruling is against the clear weight of the evidence; general assignments or a bare assertion of error are insufficient.

Questions Presented

1. Which appellate standard of review governed a workers' compensation award arising from an injury occurring on March 4, 2011?
2. Whether the statutory clear-weight-of-the-evidence standard violated the separation-of-powers doctrine.
3. What deference and briefing burden apply when an appellate party seeks review under the clear-weight-of-the-evidence standard.

Disposition

vacated