Eric Handy, Sr. v. Zurich American Insurance Company
Eric Handy, Sr. appealed the trial court's grant of a no-evidence motion for summary judgment to Zurich American Insurance Company. Handy had sought judicial review of an administrative law judge's determination that his workplace injury did not encompass disc protrusions and that he reached maximum medical improvement (MMI) with a zero-percent impairment rating. The trial court excluded Handy's untimely and unauthenticated evidence, and the appellate court affirmed this decision. The appellate court found Handy waived his arguments due to procedural non-compliance and failed to provide expert medical evidence, which is required to establish causation for complex medical conditions like disc protrusions in workers' compensation cases. Lay testimony and unauthenticated medical records were deemed insufficient to raise a genuine issue of material fact regarding causation, MMI, or impairment rating.