Harris v. Hanson Industries & Travelers Insurance

James R. Cooper,

dissenting. I dissent because I believe, that there is no substantial evidence to support the Commission’s finding that Dr. Yocum’s treatment resulted from an unauthorized change of physician. In my view, reasonable minds could, on this record, conclude only that Dr. Yocum’s treatment followed a valid referral.

We have held that a request for a referral from a treating physician does not constitute a change of physician so long as the request does not result from “doctor shopping.” TEC v. Underwood, 33 Ark. App. 116, 802 S.W.2d 481 (1991). Furthermore, in White v. Lair Oil Co.,…