Arkansas Workers Compensation Burden of Proof
When the Commission denies coverage because the claimant failed to meet his burden of proof, the substantial-evidence standard of review requires that we affirm the Commission's decision if its opinion displays a substantial basis for the denial of relief. Frances v. Gaylord Container Corp., 69 Ark. App. 26, 9 S.W.3d 550 (2000).
In determining the sufficiency of the evidence to sustain the findings of the Commission, we review the evidence in the light most favorable to the Commission's findings and affirm if they are supported by substantial evidence. Weldon v. Pierce Bros. Constr., 54 Ark. App. 344, 925 S.W.2d 179 (1996).
Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. City of Fort Smith v. Brooks, 40 Ark. App. 120, 842 S.W.2d 463 (1992).
The question is not whether the evidence would have supported findings contrary to the ones made by the Commission; there may be substantial evidence to support the Commission's decision even though we might have reached a different conclusion if we sat as the trier of fact or heard the case de novo. Tyson Foods Inc. v. Disheroon, 26 Ark. App. 145, 761 S.W.2d 617 (1988).
The Commission is not required to believe the testimony of the claimant or any other witness. Patterson v. Frito Lay, Inc., 66 Ark. App. 159, 992 S.W.2d 130 (1999).
The testimony of an interested party is always considered to be controverted. Continental Express v. Harris, 61 Ark. App. 198, 965 S.W.2d 811 (1998).
Even though the Commission is insulated to a certain degree from appellate review, its decisions are not insulated to the degree it would make appellate review meaningless. Patterson, supra. Furthermore, benefits are not always denied to a claimant who has been untruthful. Boyd v. General Industries, 22 Ark. App. 103, 733 S.W.2d 750 (1987).
We have often said that the determination of the credibility of the witnesses and the weight to be given their testimony are matters exclusively within the province of the Commission. Patterson, supra.
However, the Commission is not totally insulated from judicial review. Jordan v. J.C. Penney Co., 57 Ark. App. 174, 944 S.W.2d 547 (1997).
The Commission may not arbitrarily disregard the testimony of any witness. Boyd v. Dana Corp., 62 Ark. App. 78, 966 S.W.2d 946 (1998).