LABOR AND EMPLOYMENT LAW
In Sumpter v. Fairbanks North Star Borough School District, 494 P.3d 505 (Alaska 2021), the Supreme Court held that workers’ compensation presumption analysis does not weigh the evidence presented during the first two stages of a workers’ compensation claim. (Id. at 514). Rather, the evidence a defendant introduces to rebut a presumption of compensability is assessed separately from the evidence a claimant used to establish the presumption. (Id.). Sumpter was employed as an intensive resource teacher aide. (Id. at 508). She reported an injury to her cervical spine after she repositioned a disabled student in his wheelchair (Id.). Sumpter had serious preexisting cervical spine problems. (Id.). The Workers’ Compensation Board determined that her work was not the substantial cause of her ongoing disability and need for medical care. (Id. at 513). The Appeals Commission affirmed the determination. (Id.). Sumpter appealed, arguing that the evidence relied upon by the Board should have been weighed against the conflicting evidence she provided. (Id. at 514). The Court determined that the test used to assess the evidence proffered by the defendant is whether “a reasonable mind” could reach the conclusion that the injury is not compensable if that reasonable mind credited the evidence. (Id. at 515). The Supreme Court thus held that workers’ compensation presumption analysis does not weigh the evidence presented during the first two stages of a workers’ compensation claim. (Id. at 514).