An Arkansas appeals court ruled a ranch hand's tick-borne illness compensable, reversing a commission decision that denied the live-in employee's workers' compensation claim.
The Arkansas Court of Appeals reversed the state Workers' Compensation Commission on February 18, finding that Midwest Insurance Company must cover Jonathan Mohler's alpha-gal syndrome, a tick-borne disease that causes an allergic reaction to mammalian meat products.
The decision turns on a critical detail: Mohler lived on his employer's property and was on call twenty-four hours a day.
Mohler started work as a ranch hand at Cross Creek Ranch on or about August 3, 2020, tending cattle and maintaining fences across approximately 1,000 acres of grassland and wooded areas. His employer, Robert Young III, provided housing on the property as part of his employment. The arrangement meant Mohler was available around the clock.
In his daily work, Mohler regularly encountered ticks and removed them from his body. In late 2022, he began experiencing fatigue and vomiting that worsened over time. When he sought emergency medical treatment in January 2023, he was later diagnosed with alpha-gal syndrome after laboratory testing confirmed a positive alpha-gal panel. The condition is caused by bites from lone star or blackleg ticks and left him unable to tolerate mammalian meat products. He also experienced weight loss, slurred speech, memory problems, and difficulty concentrating.
Mohler filed for workers' compensation benefits, claiming he believed he was bitten by a tick on October 29, 2022, while repairing a fence. He acknowledged some uncertainty about the timing, testifying it was possible he removed the tick the week before or after that date. He did not report the bite to Young.
An administrative law judge ruled in Mohler's favor, but the Commission reversed that decision on April 2, 2025, in a 2-1 vote with a written dissent. The Commission found Mohler not credible regarding the alleged tick bite and his claimed work-related exposure, determining he could have been bitten on the premises outside the scope of his employment.
The appeals court disagreed. Writing for a unanimous three-judge panel, Judge Stephanie Potter Barrett noted that the compensability of a disease such as alpha-gal syndrome does not depend on identifying which tick on which date caused the condition, as requiring that level of precision would be impractical. Instead, the court analyzed the claim as an occupational disease, which requires showing that employment exposed the worker to greater risk than the general public faces.
The court found Mohler's living arrangement crucial. Because he resided on the ranch and remained on call twenty-four hours a day, he was within the time and space boundaries of his employment, even when not actively performing assigned tasks.
The decision cited a 2007 Arkansas Supreme Court case involving a hotel manager who lived on the premises and died from smoke inhalation during a fire while off duty. The court in that case examined the time and space boundaries of the employment to determine compensability and ruled the death compensable.
The appeals court also referenced two earlier Arkansas cases where occupational diseases were found compensable. In one, a teacher developed sinus issues from mold in her classroom following installation of a new heating and air-conditioning system. In another, a worker was awarded benefits for histoplasmosis after employment required daily exposure to chicken feces and areas with histoplasmosis fungus. Both faced greater disease risk than the general public.
The court noted that nothing in the record suggested an alternative explanation for Mohler's development of alpha-gal syndrome.
Medical evidence introduced at the hearing included a letter from Dr. Jantzen Slater opining that Mohler developed the syndrome from a tick bite acquired during work. The employer and carrier presented a report from Dr. Joshua Kennedy, a physician specializing in allergies and immunology, who questioned whether the documentation adequately supported a connection between Mohler's condition and a work-related tick bite due to what he believed were deficiencies and inconsistencies in the medical history.
The decision carries implications for how carriers evaluate claims from agricultural workers, groundskeepers, and others who work outdoors. It also suggests that employees who live on employer premises with on-call requirements may have broader workers' compensation coverage than those who work regular shifts and go home.
The case highlights the challenge of adjudicating occupational disease claims where pinpointing a specific incident proves impossible. Unlike workplace accidents with clear moments of injury, tick bites often go unnoticed.
For carriers writing workers' compensation policies covering outdoor workers, the decision serves as a reminder that the analysis extends beyond regular working hours. When housing is part of the employment arrangement and workers remain available continuously, the boundaries of what constitutes work-related injury expand accordingly.
