Marilyn Orr, an employee of Wal-Mart Stores, Inc., suffered a work-related accident. The Marshall Circuit Court found her permanently disabled as a result of this incident and she was granted worker's compensation benefits. Wal-Mart appealed this decision. On May 8, 2009, the Court of Civil Appeals of Alabama reversed and remanded the case.
The court found that while there was evidence of Orr’s left-knee injury causing her left-hip injury, the evidence was based on a mere possibility of causation rather than substantial evidence. This was due to the absence of clear medical testimony providing a link between Orr’s left-hip injury and the compensable injury to her left knee. As such, the court found that the trial court erred to reversal in adjudging Orr’s left-hip injury as the natural consequence of the injury to her left knee.
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