The Mississippi Court of Appeals has reversed a ruling that dismissed a workers' compensation claim filed by Sandra Thompson against her employer, Boyd Biloxi, LLC. The court's decision, issued on June 30, 2026, allows Thompson to pursue her claim for a shoulder injury she sustained while working at the casino. This ruling is significant as it clarifies when the statute of limitations begins for workers' compensation claims related to progressive injuries.
Sandra Thompson, who worked as both a dealer and supervisor at Boyd Biloxi, filed her claim after experiencing severe pain in her right shoulder. The court's decision impacts not only Thompson but also sets a precedent for other workers who may face similar challenges in proving their claims for injuries that develop over time.
Background
The dispute began when Thompson filed a petition to controvert with the Mississippi Workers’ Compensation Commission on July 13, 2024, seeking compensation for her right shoulder injury. She claimed that the injury resulted from repetitive movements associated with her job duties, including dealing cards and spinning roulette. However, Boyd Biloxi argued that Thompson's claim was barred by the two-year statute of limitations outlined in Mississippi Code Annotated section 71-3-35(1).
Thompson had been employed by Boyd Biloxi since February 2012 and had been experiencing shoulder pain since at least 2021. Despite seeking medical treatment, her condition worsened, leading to an MRI in February 2024 that revealed a labral tear and biceps tendon involvement. This diagnosis prompted her to report the injury to her supervisor in March 2024.
The Ruling
The Court of Appeals, led by Judge Carlton, ruled that the Workers’ Compensation Commission erred in dismissing Thompson's claim as time-barred. The court stated, "The record lacks the requisite 'substantial evidence' supporting this finding." The court emphasized that the statute of limitations for workers' compensation claims does not begin until the claimant recognizes the nature and seriousness of their injury.
The court found that Thompson was not aware of the compensable nature of her injury until her MRI results were discussed with her in 2024. The ruling highlighted that Thompson's earlier medical treatments for shoulder pain did not indicate a disabling injury, and it was only after the MRI that she learned about the severity of her condition and its connection to her work.
Impact
This ruling has important implications for workers' compensation claims in Mississippi, particularly for those involving progressive injuries. It clarifies that the statute of limitations begins only when a worker is aware of the compensable nature of their injury, which may not be immediately apparent. This decision could benefit other workers who experience similar situations where their injuries develop gradually over time.
The ruling also reinforces the idea that workers should not be penalized for filing claims when the nature of their injuries is not fully understood until after medical evaluations. It sets a precedent that may encourage workers to seek compensation for injuries that may not be immediately apparent.
What's Next
Thompson's case has been remanded for further proceedings, allowing her to pursue her claim with the Workers’ Compensation Commission. It is unclear if Boyd Biloxi will appeal the decision, but the outcome of this case could influence future workers' compensation claims in Mississippi.