Security National Insurance Co. v. Farmer
Roger Farmer sustained two on-the-job low back injuries in January 1995 and April 1998. Security National Insurance Company was the carrier for the first injury, and Hartford Fire Insurance Company for the second. Disputes arose regarding the compensability of Farmer's L4-5 and L5-S1 disc herniations after April 1998, and which carrier was liable. The Texas Workers’ Compensation Commission appeals panel affirmed the hearing officer's decision against Security National, finding the January 1995 injury was a producing cause. Security National appealed to the trial court, which applied a substantial evidence rule, limited discovery, and affirmed the appeals panel's decision. On appeal, the higher court determined the trial court erred by applying the incorrect standard of review, ruling that a modified de novo standard should have been used. The court reversed the trial court's judgment and remanded the case for proceedings consistent with a modified de novo review.