Missouri Supreme Court finds ConAgra not liable for worker's death

By Sara McCleary | Jan 11, 2018

JEFFERSON CITY – The Missouri Supreme Court has affirmed a decision from the Labor and Industrial Relations Commission denying a woman’s workers’ compensation claim for the death of her husband at ConAgra Packaged Foods. 

Patricia White filed a claim for workers’ compensation in January 2013 after the death of her husband, Ulysses White, on June 30, 2012. He had worked in a machine shop for ConAgra Packaged Foods. 

According to the court’s decision, written by Judge Paul C. Wilson, White had died of “a cardiac arrhythmia resulting from severe artery disease,” but the claimant argued that the immediate cause of the arrhythmia had been the working conditions, particularly the high temperature of the shop in which White worked.

The Supreme Court filed its decision on Dec. 19 after considering the commission’s decision, which had been an affirmation of an administrative law judge’s (ALJ) decision. Both the claimant and ConAgra presented testimony from expert witnesses during the ALJ hearing. 

The claimant’s expert argued the “work activities of 06/30/12 were the prevailing factor causing (White’s) cardiac arrest and death,” while ConAgra’s expert argued that his death had been caused by “underlying severe coronary artery disease and hypertensive heart disease, caused by traditional risk factors,” according to the court’s decision.

The court determined that because the commission had been presented with conflicting expert testimony, it did not err in allowing itself to be persuaded by one argument over the other. 

“In this case, the Commission was not persuaded by Dr. (Stephen) Schuman’s testimony as to whether the heat-induced strain in White’s job was the prevailing factor in causing the cardiovascular event resulting in his death and, instead, believed Dr. (Michael) Farrar’s testimony that it was not,” reads the opinion. “As a result, the Commission’s decision is supported by competent and substantial evidence and must be affirmed.”

The court rejected White’s argument that the commission should have found in her favor due to her testimony that her husband had been under excessive strain because he had worked five 12-hour shifts prior to the day of his death. The court found that the commission had been correct to dismiss White’s testimony because she lacked expert knowledge of the issue, and it was a matter “beyond the realm of lay understanding.”

Chief Justice Zel M. Fischer, and judges George W. Draper III, Mary R. Russell, Patricia Breckenridge and Laura Denvir Stith concurred. Judge W. Brent Powell did not participate.

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Conagra Brands, Inc. Missouri Supreme Court

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