TortsWorkers' CompensationWeight of the Evidenceworkers' compensationindustrial commissionmanifestly against the weight of the evidenceuncorroborated testimonyappellate review
Facts
Lane alleged that while working as a track-layer for Union Colliery Company he fell over a tie while carrying a rail and injured his left foot and right hip. He testified that he reported the injury to supervisory personnel and the company doctor, but those persons largely denied that he made such reports or described the injury as he claimed. Thompson, a witness called by Lane, recounted a different account of the incident, saying Lane stated he was hit while jacking up a car, and Kurpa gave testimony about Lane showing the doctor a swelling on his stomach. Lane's own doctor treated him the next day for a prior heel injury and rheumatism, and Lane made no complaint of any injury other than striking his sore heel against a rail.
Issue
Whether the Industrial Commission's award of compensation to Lane should stand when Lane's account of the accident and injury was uncorroborated and contradicted at multiple points by the other witnesses.
Rule
A case of this character must be considered by the court in the same manner as any other kind of case, and an Industrial Commission award must be reversed when it is manifestly against the weight of the evidence.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Springfield, Illinois, Nolan Pierce sought compensation from Prairie Rim Aggregates after claiming he twisted his knee when a pallet shifted in the warehouse. Nolan testified to that version alone, while four co-workers, the shift foreman, and a nurse from the employer's clinic all gave testimony inconsistent with his account on key points, including how the incident occurred and what injury he reported that day.
If the Industrial Commission awards Nolan benefits on this record and the employer seeks judicial review, what is the strongest argument for reversal under the majority rule?
Explanation. The majority treated a compensation case like any other case and held that an award should be reversed when it is manifestly against the weight of the evidence. The critical reasoning was that the claimant's account was unsupported by corroboration and contradicted at material points by multiple witnesses. That same combination supports reversal here. (Derived from Union Colliery Co. v. Industrial Commission (n.d.).)