In Thommen v Delta Tube and Fabricating Corp, No. 318354 (Mich Ct App April 23, 2015) the Michigan Court of Appeals ruled against a claimant's worker's compensation claim for disability arthritis, which the claimant traced back to a 1984 work injury to his left foot. Previously, the magistrate ruled in the claimant's favor, but the Michigan Compensation Appellate Commission (MCAC) reversed, finding no evidence in the record that connected the claimant's disability arthritis to the 1984 work injury. For example, the MCAC found that the claimant did not prove he suffered a fracture in 1984 and the medical professionals at issue in the case presumed a fracture precipitated the claimant's arthritis. The MCAC also characterized the claimant's injury as "some unidentified injury in 1984."

The Michigan Court of Appeals granted leave for the case and reviewed in an unpublished opinion whether there was any evidence in the record (other than evidence that had been excluded for reasons not articulated in the Court of Appeals' opinion) that established a causal connection between the claimant's 1984 injury and current arthritis. The Court of Appeals applied the "any evidence" standard to the MCAC's findings of fact, which required the Court of Appeals to treat the MCAC's factual findings as conclusive "[a]s long as there exists in the record any evidence supporting the [MCAC's] decision, and as long as the [MCAC] did not misapprehend its administrative appellate role." The Court of Appeals affirmed the MCAC's ruling, noting that while the claimant's testimony and work records indicated the claimant injured his left foot at work in 1984, there was a lack of medical records from that time, and, resultantly, the exact nature of the injury in 1984 was unknown.