Background

Richard Ford suffered a work-related shoulder injury while employed by Professional Education Services Group, LLC (PESG). The parties stipulated that Ford had reached maximum medical improvement and that the sole issue for trial was the nature and extent of his disability.

After trial, the circuit court determined that Ford was permanently and totally disabled (PTD) and awarded workers’ compensation benefits for the remainder of his natural life. The employer appealed, challenging both the sufficiency of the evidence supporting the PTD finding and the lifetime aspect of the award.

The Court’s Holding

The Court of Civil Appeals affirmed in part and reversed in part:

The court affirmed the finding of permanent total disability due to his shoulder injury, concluding that testimony about Ford’s ongoing pain and inability to work, combined with vocational and medical evidence, was substantial evidence supporting that finding.

However, the court reversed the portion of the judgment awarding benefits for the remainder of Ford’s natural life, holding that compensation for PTD is limited to the duration of the disability, which is not necessarily the employee’s lifetime.

Why This Case Matters

This decision underscores two important principles in Alabama workers’ compensation law:

Trial courts retain broad discretion in determining permanent total disability when supported by substantial evidence.

Even when PTD is properly established, the structure and duration of benefit awards must strictly comply with statutory authority.