Disability benefits; Whether a workplace incident was a significant element in an allegedly disabling condition; MCL 418.301(2); Martin v Pontiac Sch Dist (MCAC); Yost v Detroit Bd of Educ (MCAC); Whether the magistrate’s findings of fact were supported by competent, material, & substantial evidence on the whole record; MCL 418.861a(3); Mudel v Great Atl & Pac Tea Co; Whether the Martin test is at odds with the principle that a preexisting condition is not a bar to eligibility for workers’ compensation benefits & conflicts with the plain meaning of MCL 418.301(2); Gardner v Van Buren Pub Schs; Farrington v Total Petroleum Inc

The court held that the MCAC did not err by reversing the magistrate’s order denying plaintiff-employee disability benefits based on a work-related injury, or by affirming, in pertinent part, the magistrate’s determination that plaintiff failed to show her mental health issues were significantly contributed to by her workplace accident. It also concluded that there were no grounds to overturn the MCAC’s Martin test. Plaintiff sought disability benefits after a work incident in which she received an electric shock, fell off a ladder, and hit her shoulder and head. The magistrate found that she failed to establish a limitation in her wage-earning capacity in work suitable to her qualifications and training, and that the nonoccupational triggers leading to her disability outnumbered the occupational ones. The MCAC reversed as to the shoulder injury, but affirmed as to her mental health issues. The court denied leave, but the Supreme Court remanded. On remand, the court first found that the MCAC used “a proper standard of law when analyzing the magistrate’s decision regarding causation.” It set forth the proper standards, and noted it “could not simply substitute its judgment for that of the magistrate if competent, material, and substantial evidence supported the magistrate’s findings.” The court next found that the MCAC correctly concluded that the magistrate properly applied the four-factor Martin test and the Yost factors, noting its acceptance of the magistrate’s analysis of the various factors was proper. “While the evidence produced could also have led to the contrary conclusion, it is not the role of this Court to overturn a decision supported by the evidence in a workers’ compensation case.” Finally, the court found that the Martin test is not “at odds with the principle that a preexisting condition is not a bar to eligibility for workers’ compensation benefits” and does not conflict with the plain meaning of MCL 418.301(2). “We cannot conclude that the Martin test conflicts with the plain language of MCL 418.301(2) when it essentially conforms with the Supreme Court’s own guidance regarding how to apply that statute—i.e., it provides for a comparison of nonemployment and employment factors. Indeed, analyzing the number of stressors, the relative amount they contribute to a condition, the various stressors’ duration, and the extent of the stressors’ permanent effect essentially implements the language from Gardner and Farrington.” Affirmed.