Layman v. Newkirk Electric Associates, Inc

In Layman v. Newkirk Electric Associates, Inc, 458 Mich. 494; 581 N.W.2d 244 (1998), a magistrate awarded benefits for work-related disability, but the magistrate did not make any specific finding whether the plaintiff's disabling arthritis was a condition of the aging process subject to the significant-manner standard of work-relatedness set forth in subsection 301(2) of the Worker's Disability Compensation Act (WDCA), nor did the magistrate expressly apply the significant-manner test. On appeal, the WCAC did not determine whether the magistrate's findings were supported by the requisite competent, material, and substantial evidence on the whole record, because it concluded that the magistrate applied the wrong legal standard, i.e., the less stringent standard of work-relatedness set forth in subsection 301(1) of the WDCA. Layman, 458 Mich. at 502. The WCAC then proceeded to reverse the award of benefits on the basis of its own determination that the more stringent significant-manner test of work-relatedness had not been met. 458 Mich. at 503. The Michigan Supreme Court vacated the WCAC's decision and remanded the case to the magistrate, stating that the WCAC had engaged in improper fact finding when it should have remanded the case to the magistrate for further findings according to the proper legal standards. 458 Mich. at 507-509. In this regard, the Supreme Court held that when a magistrate fails to make sufficient findings concerning matters essential to a proper resolution of the case, the WCAC may not make findings of its own, but must remand the case to the magistrate to make the relevant findings in the first instance. 458 Mich. at 509. The Court also cautioned against making "alternative findings" when reviewing the magistrate's decision on appeal. 458 Mich. at 507.