Alabama Supreme Court Reverses Court of Civil Appeals Holding in Ex parte Caldwell
On July 20, 2012, the Alabama Supreme Court released its opinion in Ex parte Caldwell (In re: West Fraser, Inc. v. Windell Caldwell, Sr.), reversing the earlier January 13, 2012 holding of the Alabama Court of Civil Appeals in that case. (See our January 23, 2012 blog post Finding of Compensability Reversed Where Burden of Proof not Satisfied for a summary of the earlier opinion). In its holding, the Supreme Court held that the lower court erred by re-weighing the evidence presented to the trial court. Citing Ex parte McInish, 47 So.3d 778, the Supreme Court stated that "in reviewing a decision of the trial court, an appellate court is not permitted to re-weigh the evidence, because weighing the evidence is solely a function of the trier of fact." The Supreme Court noted that the only function the appellate courts have in their review of workers’ compensation cases is to ascertain whether any substantial evidence existed that could support the trial court’s findings of facts. Since the trial court found Caldwell’s testimony credible, the Supreme Court held that Caldwell’s testimony constituted evidence of such weight and quality that fair-minded persons in the exercise of impartial judgment could reasonably infer that Caldwell’s injuries were work-related.