Morris v. Jackson Clinic Prof’l Assoc.

Employee injured her right shoulder in the course of her employment with Employer. Employee received medical treatment, during which time she continued to work for Employer. Employee filed a complaint in chancery court seeking workers' compensation benefits from her Employer. At trial, the parties contested the extent of Employee's anatomical impairment and permanent disability. The medical evidence at trial consisted of the testimony of two physicians, and through their testimony, the parties introduced Employee's medical records generated by other treating physicians. The physicians assigned varying degrees of impairment to the body as whole. The trial court eventually chose the evaluating physician's impairment, who assigned a seventeen percent impairment, and awarded Employee 25.5 percent permanent partial disability to the body as a whole. Employer appealed, arguing that the evaluating physician's rating did not comply with the American Medical Association Guides and that the award was therefore excessive. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by accepting the evaluating physician's impairment rating as the basis of the disability award.