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Autozone, Inc. et al. v. Mesa

The superior court exceeded its authority when it substituted itself as the factfinder in lieu of an administrative law judge and the State Board of Workers' Compensation and reversed the Board's ruling, which denied certain benefits to the claimant.

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Reese, Judge.The Appellant, Autozone, Inc., seeks review of a judgment of the Superior Court of Columbia County that reversed a ruling of the State Board of Workers’ Compensation (“Board”), which denied certain benefits to the Appellee, Eulalia Mesa.[1] The Appellant contends that the superior court misapplied the “any evidence” standard when reviewing the Board’s ruling and erred in finding that the Administrative Law Judge (“ALJ”), who initially denied the Appellee’s claim, acted “contrary to law.” For the reasons set forth, infra, we reverse.

Viewed in the light most favorable to the Appellant, as the party who prevailed before the Board,[2] the record reveals the following, undisputed facts.[3] In November 2010, while the Appellee was working for the Appellant as a clerk and delivery driver, the truck the Appellee was driving was “rear-ended” by another car, and the accident injured her back and neck. She was treated in an emergency room, followed by outpatient treatment, during which several physicians diagnosed her with neck and lower back pain. Shortly after the accident, the Appellee returned to fully paid, full-time work for the Appellant in a light-duty status, performing only clerical duties because her medication made her too dizzy to drive a delivery truck. In January 2011, a treating physician cleared her to drive the delivery truck, and she resumed her delivery duties for the Appellant.

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