“Sparse” Workers’ Compensation Order Prevents Mandamus Review

The trial court decided that a nursing-home employee was entitled to workers’ compensation benefits. The court’s order “did not contain detailed findings of fact and conclusions of law,” as required by Ala. Code § 25-5-88. This “sparse” order prevented appellate review. The Court of Civil Appeals denied the employer’s mandamus petition and ordered the trial court to enter an order complying with § 25-5-88. El Reposo Nursing Home Group, Inc., No. 2100113 (Ala. Civ. App. Mar. 25, 2011).

A nursing home assistant was injured while working. Her employer refused to provide workers’ compensation benefits. Two doctors had determined that her injuries preexisted the workplace accident, and that her primary insurer should therefore pay for any needed treatment. The trial court disagreed. It found that the employee had suffered a work-related injury and ordered the employer to provide medical benefits. The employer petitioned the Court of Civil Appeals for a writ of mandamus.

The appellate court found the lower court’s order insufficient to support mandamus review. That order “did not contain detailed findings of fact and conclusions of law,” as required by § 25-5-88 of the workers’ compensation laws. This made review of the lower court’s decision “difficult if not impossible.” The appellate court noted that it had “repeatedly” reversed trial-court judgments, and denied attendant mandamus petitions, in cases where trial-court orders were similarly wanting. It did so again here. Denying the employer’s petition, the Court of Civil Appeals ordered the lower court to enter an order that set out the detail that § 25-5-88 requires. Once the lower court entered that order, the employer could “again petition . . . for a writ of mandamus.”