Brown Mechanical Contractors, Inc v. James Maughon

CourtCourt of Appeals of Georgia
DecidedMay 31, 2012
DocketA12A0782
StatusPublished

This text of Brown Mechanical Contractors, Inc v. James Maughon (Brown Mechanical Contractors, Inc v. James Maughon) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown Mechanical Contractors, Inc v. James Maughon, (Ga. Ct. App. 2012).

Opinion

FOURTH DIVISION DOYLE, P. J., ANDREWS and BOGGS, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

May 31, 2012

In the Court of Appeals of Georgia A12A0782. BROWN MECHANICAL CONTRACTORS, INC. et al. BO-036 v. MAUGHON.

BOGGS, Judge.

In this discretionary appeal, Brown Mechanical Contractors and Liberty Mutual

Insurance Company (collectively “the employer”) appeal from a superior court order

reversing the decision of the appellate division of the State Board of Workers’

Compensation (“the Board”) and reinstating the decision of the administrative law

judge (“ALJ”) to award temporary total disability benefits. The employer contends

that the superior court erred by applying a de novo standard of review instead of the

“any evidence” standard of review. It also asserts that the trial court failed to review

and revise an order prepared by Maughon’s attorney. We find merit in the employer’s

standard-of-review argument and therefore reverse. The issue in this workers’ compensation case is whether Maughon is entitled

to temporary total disability benefits after he was laid off from his employment with

Brown Mechanical on April 1, 2010. Brown Mechanical laid off Maughon for

reasons unrelated to his disability. At the time of his lay-off, Maughon was working

as a track hoe operator with restrictions against lifting, pushing, pulling or carrying

over 40 pounds with his right arm or hand and any over-the-shoulder height work

with his right arm or hand. The restrictions resulted from an on-the-job injury that

occurred on February 15, 2010. Following his lay-off, Maughon looked for work with

“well over 100” employers between April 1, 2010 and October 20, 1010, the date of

the hearing on his claim. Maughon provided a job search log documenting his

activities during this time period. Maughon testified that he received three job offers

that were rescinded after he disclosed his injury and work restrictions.

The ALJ determined that Maughon was entitled to temporary total disability

benefits and rejected the employer’s argument that Maughon did not make a diligent

job search. The employer appealed to the Board, which vacated the ALJ’s decision

and denied Maughon’s claim for benefits.

The Board concluded that Maughon had not engaged in a diligent job search

based upon the following facts: “110 searches over 144 ‘work days’ (excluding

2 holidays and weekends) is not sufficient;” “engaging in a ‘job search,’ on average,

less than one time per day is not a diligent job search,” Maughon’s work log showed

a lack of follow-up with 22 potential employers; Maughon failed to search for periods

of time lasting 27 and 18 consecutive days; Maughon lost two offered positions due

to the need for surgery that had not been scheduled; Maughon’s job search

concentrated on jobs involving physical labor when his employment history included

managerial/sales experience; and Maughon’s failure to seek retail jobs supported an

inference that he “was attempting to avoid being hired in order to bolster his claim

for indemnity benefits.” Based upon all of these facts, the Board concluded that the

record did not provide “support for ‘reasonable inferences’ to be drawn that his

inability to find work is due to the work injury.”

Maughon appealed the Board’s ruling to the Monroe County Superior Court,

which orally announced its decision to reinstate the ALJ’s award of temporary total

disability benefits at the conclusion of a hearing. At the trial court’s request,

Maughon’s counsel prepared an order concluding that the Board misapplied the

Supreme Court of Georgia’s decision in Maloney v. Gordon Farms, 265 Ga. 825 (462

SE2d 606) (1995), when it vacated the ALJ’s decision. The order prepared by counsel

and adopted by the superior court concluded that the proper standard of review was

3 de novo because the Appellate Division erred in applying the law, specifically the

Supreme Court’s decision in Maloney, supra. According to the superior court, the

Board established “a heightened burden of proof not required by Maloney.”

This court granted the employer’s application for discretionary review, and we

will first determine whether the superior court applied the proper standard of review.

1. In Maloney, supra, the Supreme Court addressed a claimant’s burden of

proof in change-of-condition cases and held:

In order to receive workers’ compensation benefits based on a change in condition, a claimant must establish by a preponderance of the evidence that he or she suffered a loss of earning power as a result of a compensable work-related injury; continues to suffer physical limitations attributable to that injury; and has made a diligent, but unsuccessful effort to secure suitable employment following termination. Once evidence is offered in support of the foregoing, the board may in its discretion draw reasonable inferences from that evidence that despite the claimant’s good faith efforts, his or her inability to obtain suitable employment was proximately caused by the continuing disability.

265 Ga. at 828. It also overruled our decisions in Aden’s Minit Market v. Landon, 202

Ga. App. 219 (413 SE2d 738) (1991), and Autolite v. Glaze, 211 Ga. App. 780 (440

SE2d 497) (1994), to the extent they “impose[d] an additional burden on the claimant

4 to prove the reasons why he or she was not hired by a prospective employer.” 265 Ga.

at 828. And, it concluded that in the case before it, Maloney had “proved by a

preponderance of the evidence that she suffered an economic change in condition.”

Id. It therefore reversed this Court’s decision to reverse the ALJ’s decision to resume

benefits that had been adopted by the Board and affirmed by operation of law in

superior court. Id. at 829-830. See Gordon County Farms v. Maloney, 214 Ga. App.

253, 255 (1) (447 SE2d 623) (1994) (reversing award of benefits because employee

failed to submit proof as to reasons why prospective employers failed to hire her),

overruled by Maloney, supra. In Diamond Rug & Carpet Mills v. Moses, 221 Ga.

App. 807, 809 (472 SE2d 565) (1996), we held that Maloney should also be applied

to “all issues” cases the like the one presently before us. Id. at 809 (“all issues” cases

are ones in which the claimant did not miss seven days or more of work with the

employer due to his injury before being laid off).

Following the Supreme Court’s decision in Maloney, this court has clarified

the standard of review with regard to the issue of whether a claimant has established

by a preponderance of the evidence that he has made a diligent, but unsuccessful

effort, to secure suitable employment. First,

5 [o]nce the claimant shows that she has made diligent but unsuccessful efforts to obtain suitable employment, the factfinder may, in its discretion, infer from the evidence that the claimant’s disability is the proximate cause of her unemployment. However, Maloney does not require the factfinder to draw this inference, and it is not an abuse of discretion for it to make an alternative inference. That is, the factfinder could properly infer that the claimant’s continuing unemployment was due to a number of reasons other than her disability.

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Related

Bankhead Enterprises v. Beavers
480 S.E.2d 840 (Supreme Court of Georgia, 1997)
Autolite v. Glaze
440 S.E.2d 497 (Court of Appeals of Georgia, 1994)
Gordon County Farm v. Maloney
447 S.E.2d 623 (Court of Appeals of Georgia, 1994)
McEver v. Worrell Enterprises
478 S.E.2d 445 (Court of Appeals of Georgia, 1996)
Aden's Minit Market v. Landon
413 S.E.2d 738 (Court of Appeals of Georgia, 1991)
Diamond Rug & Carpet Mills v. Moses
472 S.E.2d 565 (Court of Appeals of Georgia, 1996)
L.C.P. Chemicals v. Strickland
472 S.E.2d 471 (Court of Appeals of Georgia, 1996)
Maloney v. Gordon County Farms
462 S.E.2d 606 (Supreme Court of Georgia, 1995)
Master Craft Flooring v. Dunham
708 S.E.2d 36 (Court of Appeals of Georgia, 2011)
Donnelley v. Ogletree
718 S.E.2d 825 (Court of Appeals of Georgia, 2011)

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