Salenbien v. Arrow Uniform, Mich. Ct. of Appeals (2010)
This case concerns a salesman that was traveling on a Michigan highway and was involved in a motor-vehicle accident causing undisputed injuries after departing a prospective client’s place of business. The injured employee testified that he could not recall whether he was heading home or whether he was returning to work. The magistrate held that the claimant failed to prove that he was within the course and scope of his employment based on the testimony. The WCAC upheld the decision, applying the substantial evidence standard, in its determination that the magistrate’s findings and decision were supported. The Court of Appeals overturned the WCAC and remanded to the magistrate for additional proceedings consistent with their opinion.

Key Point: The Court of Appeals must apply the “any evidence” standard when reviewing questions of fact on appeal from the WCAC. Here, they seemingly ignored this standard and reversed the WCAC and magistrate based on their own interpretation of the facts rather than deferring to “any evidence” that would support the WCAC’s finding.