Patricia Smith Parker v. Canton Manor and Mississippi Health Care Association

CourtCourt of Appeals of Mississippi
DecidedMay 2, 2023
Docket2022-WC-00206-COA
StatusPublished

This text of Patricia Smith Parker v. Canton Manor and Mississippi Health Care Association (Patricia Smith Parker v. Canton Manor and Mississippi Health Care Association) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patricia Smith Parker v. Canton Manor and Mississippi Health Care Association, (Mich. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2022-WC-00206-COA

PATRICIA SMITH PARKER APPELLANT

v.

CANTON MANOR AND MISSISSIPPI HEALTH APPELLEES CARE ASSOCIATION

DATE OF JUDGMENT: 02/01/2022 TRIBUNAL FROM WHICH MISSISSIPPI WORKERS’ APPEALED: COMPENSATION COMMISSION ATTORNEYS FOR APPELLANT: BENNIE L. JONES JR. ROBERTA LYNN HAUGHTON ATTORNEYS FOR APPELLEES: BETTY B. ARINDER LANA E. GILLON NATURE OF THE CASE: CIVIL - WORKERS’ COMPENSATION DISPOSITION: REVERSED AND REMANDED - 05/02/2023 MOTION FOR REHEARING FILED:

CONSOLIDATED WITH

NO. 2022-WC-00207-COA

CANTON MANOR AND MISSISSIPPI HEALTH APPELLEES CARE ASSOCIATION

DATE OF JUDGMENT: 02/01/2022 TRIBUNAL FROM WHICH MISSISSIPPI WORKERS’ APPEALED: COMPENSATION COMMISSION ATTORNEYS FOR APPELLANT: BENNIE L. JONES JR. ROBERTA LYNN HAUGHTON ATTORNEYS FOR APPELLEES: BETTY B. ARINDER LANA E. GILLON NATURE OF THE CASE: CIVIL - WORKERS’ COMPENSATION DISPOSITION: REVERSED AND REMANDED - 05/02/2023 MOTION FOR REHEARING FILED:

EN BANC.

WILSON, P.J., FOR THE COURT:

¶1. Patricia Smith Parker filed two workers’ compensation claims. She alleged that she

had been injured in two workplace incidents and that the disabling character of her injuries

did not become apparent until less than two years before she filed her claims. Accepting

those allegations as true, Parker’s claims are not barred by the applicable two-year statute of

limitations. However, Parker’s employer/carrier Canton Manor and the Mississippi Health

Care Association (collectively, “Canton Manor”) moved to dismiss Parker’s claims, arguing

that they were time-barred. Although Canton Manor presented no evidence in support of its

affirmative defense, the Workers’ Compensation Commission accepted Canton Manor’s

argument and dismissed Parker’s claims. We hold that the Commission erred by dismissing

Parker’s claims because Parker alleged facts that, if true, were sufficient to bring her claims

within the statute of limitations, and Canton Manor presented no evidence to meet its burden

of proving its affirmative defense. Therefore, we reverse the Commission’s orders and

remand for further proceedings consistent with this opinion.

FACTS AND PROCEDURAL HISTORY

¶2. On June 7, 2021, Parker filed two petitions to controvert with the Commission. Her

first petition alleged that on December 11, 2018, while she was employed at Canton Manor,

a nursing home, she “was grabbed around her neck and thrown to the floor by a resident,”

and the resident “grabbed her by her neck [again] as she tried to get up.” Parker alleged that

2 she “experienced discomfort immediately after the incident.” However, Parker alleged that

she did not begin to experience “severe pain . . . due to the totality of [this and other]

previous injuries” until May 3, 2020. Parker also alleged that her period of temporary

disability began on May 3, 2020.

¶3. Parker’s second petition alleged that on April 18, 2019, while she was employed at

Canton Manor, “[a] resident hit her shoulder with excessive force.” Parker alleged that her

“shoulder was injured and bruised[,] . . . and she experienced extreme burning.” However,

Parker alleged that she did not begin to experience “severe pain . . . due to the totality of [this

and other] previous injuries” until May 3, 2020. Parker also alleged that her period of

temporary disability began on May 3, 2020.

¶4. Canton Manor answered and alleged that Parker’s claims were barred by the statute

of limitations. Canton Manor then filed nearly identical one-page motions to dismiss,

arguing the statute of limitations barred Parker’s claims because each was filed more than

two years after the date of her injury, and no compensation had been paid. See Miss. Code

Ann. § 71-3-35(1) (Rev. 2021). In response, Parker argued that her claims were timely

because each was filed within two years of the time when the compensable nature of her

injury became reasonably apparent to her. Neither party submitted any evidence or requested

an evidentiary hearing. A telephonic hearing was held before the administrative judge (AJ)

but was not transcribed. The AJ then issued nearly identical orders dismissing each case.

The AJ found that Parker “was fully aware that she sustained an injury at work on” the date

of each underlying incident, that neither injury was “a latent injury,” and that the statute of

3 limitations barred both claims.

¶5. Parker filed a petition for review by the full Commission in both cases, and Canton

Manor responded. Canton Manor attached minutes from its “Safety Committee” meeting

dated December 28, 2018, as Exhibit A to its response in the first case. According to Canton

Manor, the minutes document the December 2018 incident involving Parker as follows:

“resident playing too rough & staff & resident went to floor.” Canton Manor attached an

employee incident report dated April 1, 2019, as Exhibit A to its response in the second case.

According to Canton Manor, the incident report documents the April 2019 incident involving

Parker, although it does not match the date alleged in Parker’s petition. The incident report

states that a resident “hit” Parker, resulting in “redness/swelling to [Parker’s] right upper

arm.” Canton Manor did not file a motion to introduce additional evidence before the full

Commission, as required by the Commission’s rules. See Miss. Workers’ Comp. Comm’n

Proc. R. 9; Short v. Wilson Meat House LLC, 36 So. 3d 1247, 1254 (¶¶34-35) (Miss. 2010).

The Commission subsequently entered one-page orders affirming the AJ’s decisions and

dismissing Parker’s claims with no additional analysis. Parker appealed from both final

judgments, and this Court consolidated her two appeals.

ANALYSIS

¶6. The sole issue in this appeal is whether the Commission properly dismissed Parker’s

claims because they are barred by the statute of limitations.1 In general, a workers’

1 In general, we review the decision of the Commission, not the AJ. Sheffield v. S.J. Louis Constr. Inc., 285 So. 3d 614, 618 (¶8) (Miss. 2019). However, we review the AJ’s decision when, as in this case, the Commission summarily affirmed the AJ “without additional analysis.” Duren v. Effex Mgmt. Sols. LLC, 342 So. 3d 481, 488 (¶31) (Miss. Ct.

4 compensation claim must be “filed . . . within two (2) years from the date of the injury.”

Miss. Code Ann. § 71-3-35(1). However, the Mississippi Supreme Court has held that “[t]he

word ‘injury’ in the two-year statute refers to a compensable injury.” Quaker Oats Co. v.

Miller, 370 So. 2d 1363, 1365 (Miss. 1979) (emphasis added) (quoting Pepsi Cola Bottling

Co. of Tupelo Inc. v. Long, 362 So. 2d 182, 185 (Miss. 1978)). Therefore, “the statute of

limitations does not begin to run until by reasonable care and diligence it is discoverable and

apparent that a compensable injury has been sustained.” Id. (quoting Tabor Motor Co. v.

Garrard, 233 So. 2d 811, 814 (Miss. 1970)). The Supreme Court has further clarified that

a “compensable injury” is a “disabling injury” that occurred at work.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Cooper v. DEPT. OF REHABILITATION SERVICES
937 So. 2d 51 (Court of Appeals of Mississippi, 2006)
Shipp v. THOMAS AND BETTS
13 So. 3d 332 (Court of Appeals of Mississippi, 2009)
Baker v. IGA Super Valu Food Store
990 So. 2d 254 (Court of Appeals of Mississippi, 2008)
Mid-Delta Home Health, Inc. v. Robertson
749 So. 2d 379 (Court of Appeals of Mississippi, 1999)
Weeks v. Mississippi College
749 So. 2d 1082 (Court of Appeals of Mississippi, 1999)
PEPSI COLA BOTTLING CO., ETC. v. Long
362 So. 2d 182 (Mississippi Supreme Court, 1978)
Quaker Oats Co. v. Miller
370 So. 2d 1363 (Mississippi Supreme Court, 1979)
Huss v. Gayden
991 So. 2d 162 (Mississippi Supreme Court, 2008)
JH Moon & Sons, Inc. v. Johnson
753 So. 2d 445 (Mississippi Supreme Court, 1999)
Tabor Motor Company v. Garrard
233 So. 2d 811 (Mississippi Supreme Court, 1970)
Estate of Johnson v. Graceland Care Center of Oxford, LLC
41 So. 3d 692 (Mississippi Supreme Court, 2010)
Short v. Wilson Meat House, LLC
36 So. 3d 1247 (Mississippi Supreme Court, 2010)
City of Vicksburg, Mississippi v. Herbert A. Williams
191 So. 3d 1242 (Mississippi Supreme Court, 2016)
Smith v. Nissan North America
102 So. 3d 321 (Court of Appeals of Mississippi, 2012)
Mabus v. Mueller Industries, Inc.
205 So. 3d 677 (Court of Appeals of Mississippi, 2016)
Cooper's, Inc. v. Long
224 So. 2d 866 (Mississippi Supreme Court, 1969)

Cite This Page — Counsel Stack

Bluebook (online)
Patricia Smith Parker v. Canton Manor and Mississippi Health Care Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patricia-smith-parker-v-canton-manor-and-mississippi-health-care-missctapp-2023.