Howard Industries, Inc. v. Selina Hayes

CourtMississippi Supreme Court
DecidedOctober 19, 2023
Docket2021-CT-00694-SCT
StatusPublished

This text of Howard Industries, Inc. v. Selina Hayes (Howard Industries, Inc. v. Selina Hayes) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Howard Industries, Inc. v. Selina Hayes, (Mich. 2023).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2021-CT-00694-SCT

HOWARD INDUSTRIES, INC.

v.

SELINA HAYES ON WRIT OF CERTIORARI

DATE OF JUDGMENT: 05/19/2021 TRIBUNAL FROM WHICH MISSISSIPPI WORKERS’ COMPENSATION APPEALED: COMMISSION ATTORNEYS FOR APPELLANT: ROBERT P. THOMPSON LAURA WALSH GIVENS ATTORNEYS FOR APPELLEE: ROGER K. DOOLITTLE FLOYD E. DOOLITTLE NATURE OF THE CASE: CIVIL - WORKERS’ COMPENSATION DISPOSITION: ON DIRECT APPEAL: AFFIRMED. ON CROSS-APPEAL: AFFIRMED - 10/19/2023 MOTION FOR REHEARING FILED:

CONSOLIDATED WITH

NO. 2021-CT-00695-SCT

SELINA HAYES

DATE OF JUDGMENT: 05/19/2021 TRIBUNAL FROM WHICH MISSISSIPPI WORKERS’ COMPENSATION APPEALED: COMMISSION ATTORNEYS FOR APPELLANT: ROBERT P. THOMPSON LAURA WALSH GIVENS ATTORNEYS FOR APPELLEE: ROGER K. DOOLITTLE FLOYD E. DOOLITTLE NATURE OF THE CASE: CIVIL - WORKERS’ COMPENSATION DISPOSITION: ON DIRECT APPEAL: AFFIRMED. ON CROSS-APPEAL: AFFIRMED - 10/19/2023 MOTION FOR REHEARING FILED:

EN BANC.

KITCHENS, PRESIDING JUSTICE, FOR THE COURT:

¶1. The Workers’ Compensation Commission imposed a $1,000 sanction against an

employer’s attorney for submitting misleading documentation to an Administrative Judge

(AJ).1 The Court of Appeals affirmed the sanction and the Commission’s award of permanent

disability benefits to the employee.2 On certiorari review, we agree with the Court of

Appeals that the sanction should be affirmed.

STATEMENT OF THE FACTS

¶2. Longtime Howard Industries employee Selina Hayes filed two workers’ compensation

claims related to injuries incurred during her work as a coil winder.3 The coil winder job

required lifting twenty to one hundred pounds of coiled wire above shoulder level. In the first

injury, Hayes tripped and fell, injuring her head, neck, shoulder, and back. In the second

injury, Hayes injured her right shoulder while lifting wire over her head. The second injury

1 The AJ imposed the sanction against the employer, but on review the Commission placed the sanction solely on the individual attorney. 2 The Court of Appeals’ lengthy opinion is thorough and convincing. Howard Indus. Inc. v. Hayes, No. 2021-WC-00694-COA, 2022 WL 6640398 (Miss. Ct. App. Oct. 11, 2022). Our certiorari review is limited to addressing the imposition of the sanction. 3 The first injury occurred in 2007 and the second in 2015. The claims were consolidated below.

2 required surgery. Hayes returned to work after reaching maximum medical improvement

(MMI). However, due to medical restrictions on her ability to lift weight over her head,

Hayes was moved to the position of coil winder trainer. As a further accommodation, Hayes

was restricted to working forty hours a week, even though consistent with the union contract,

Howard Industries requires coil winder trainers to work overtime for as much as twenty hours

a week.

¶3. The AJ’s determination of whether Hayes suffered a loss of earning capacity

necessitated comparison of the coil winder position to the position of coil winder trainer.

Howard Industries took the position that Hayes did not suffer a loss of wage-earning capacity

because she returned to work after the second injury at a higher hourly rate than she had

previously earned. Howard Industries hired Peter Mills as an expert to prepare a job analysis

of the position of coil winder trainer. Mills’s first report, filed in a pre-hearing statement,

included a form titled “Job Analysis Re: Selina Hayes.” The form had blank spaces that Mills

had filled in. The form listed the “Exact Job Title: Coil Winder Trainer - Dept. 131,”

“Training Required to Perform Duties,” “Essential Job Responsibilities,” and the hours

required. Mills had filled in “Work Hours (time) 7:00 am to 5:30 pm” “6 days per week” and

“Overtime: hrs. per week Subject to overtime - approximately 20 hrs. per week.” The form

listed the physical requirements of the job. Mills had checked “no” on a box indicating the

job could not be modified temporarily or permanently.

¶4. However, Howard Industries attorney Richard Lewis Yoder submitted a supplemental

3 pre-hearing statement with a “corrected Job Analysis.” Attached was a modified job analysis

form from Mills, again entitled “Job Analysis Re: Selina Hayes.” The form was the same in

all respects except it altered the time requirements for the coil winder trainer job. It listed

“Work Hours (time) 7:00 am to 3:30 pm,” “5 days per week.” The box for “Overtime: hrs.

per week” was left blank. Therefore, the modified form showed five days, not six, and no

overtime. It said the job could not be modified temporarily or permanently.

¶5. At the initial hearing on Hayes’s claims before the AJ, Hayes’s attorney questioned

Mills on the discrepancy between the two reports. As the Court of Appeals’ opinion

summarizes:

¶18. Hayes called Howard Industries’[] expert Mills as her first witness. After being questioned about his company, the extent of work done for Howard Industries, and the income received from that work, Mills testified about Exhibit 14, the vocational report that Howard Industries provided on May 2, 2019. In the written portion of that report, Mills said that he was retained to perform “a job analysis of the position of coil winder trainer at Howard Industries, Department 131.” He said that he visited the facility on February 26, 2019. During this two-hour visit, Mills spoke to Elton Buxton (supervisor), Walter Todd (supervisor and general foreman), and John Risher (health and safety manager). Mills also observed what coil winder trainers did. Mills said his job was to provide a job analysis of a coil winder trainer, which included an evaluation of the job’s physical demands.

¶19. Hayes’[s] attorney then presented Mills with his initial report with its initial attachment provided by Howard Industries on April 30, 2019, which was entered into evidence as Exhibit 17. Mills admitted that the attachment to this initial report indicated that trainers work six days a week with approximately twenty hours of overtime, although he said he did not confirm this with the employees he had spoken to at the facility. He testified that Hayes did what all other trainers did, except she was only allowed to work five days a week. Mills agreed that other trainers worked overtime as noted in the initial attachment to his written report and that he did not know, but would not

4 dispute, that coil winder trainers averaged between twenty-one and twenty-three hours a week. Contradicting the written portion of his report that stated he had been retained to evaluate the job of coil winder trainer, Mills then testified that the first attachment to his written report was a “mistake” and that he meant to evaluate the job given to Hayes as a specific accommodation for her alone, not what the general position of coil winder trainer entailed. Mills and Hayes’s attorney continued discussing what Mills then characterized as “clerical errors” made in the first attachment to the report. Mills testified that the hours, days, and overtime worked in the that first attachment were “typographical error[s]” put in accidentally. Mills confirmed that he made no change to the written portion of his report to note that it was “revised” or “amended” in any way to indicate that it was now an evaluation of only the job given to Hayes to accommodate all her restrictions. Mills agreed that using the initial attachment to his report, Hayes could not perform the trainer’s job from the standpoint of hours. Mills also said that he changed the report because Howard Industries’s attorney Yoder called him and told him the information was incorrect.

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Howard Industries, Inc. v. Selina Hayes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-industries-inc-v-selina-hayes-miss-2023.