Wilkinson County Bd. of Educ. v. Johnson

Following the death of her husband, Violet Johnson sought dependent’s benefits from her husband’s employer, the Wilkinson County Board of Education. After an administrative-law judge and the State Board of Workers’ Compensation the “Board” denied her claim, Mrs. Johnson appealed to the superior court, which reversed the Board’s ruling and remanded the case to the ALJ for further consideration. Wilkinson County now appeals, arguing that the superior court erred in ruling that Mrs. Johnson was entitled to the presumption that her husband’s death arose out of and in the course of his employment, in finding that Mr. Johnson’s death occurred when he was performing his job duties, and in remanding the case to the ALJ for a determination of whether Mr. Johnson’s death was the result of his employment aggravating a pre-existing medical condition. Because the superior court, the Board, and the ALJ misapplied the law in determining whether Mrs. Johnson was entitled to the presumption that her husband’s death arose out of his employment, we vacate the superior court’s order, as well as the Board and the ALJ’s rulings. Accordingly, we remand the case to the ALJ for further consideration consistent with this opinion.

At the outset, we note that in reviewing a workers’ compensation award, this Court must construe the evidence “in the light most favorable to the party prevailing before the appellate division.”1 In addition, the findings of the State Board of Workers’ Compensation, when supported by any evidence, are “conclusive and binding, and neither the superior court nor this Court may substitute itself as a factfinding body in lieu of the State Board.”2 But erroneous applications of law to undisputed facts, as well as decisions based on erroneous theories of law, are “subject to a de novo standard of review.”3 And when it is determined that the Board or the ALJ decided the case on an erroneous legal theory or improperly applied the law to the facts, the proper course of action is for this Court to remand the case to the ALJ for further findings and consideration.4