Alabama Supreme Court Addresses Unexplained Fall At Work
Last week, the Alabama Supreme Court issued it's opinion in the case of Ex Parte Patsy Patton d/b/a Korner Store (In re Lana T. Brown v. Patsy Patton d/b/a Korner Store). Ms. Brown worked as a cashier at the Korner Store, which is a gas station/convenience store. She walked to the deli counter to refill her coffee cup, and when she began walking back to the front of the store, she "inexplicably fell, breaking her wrist". She filed a workers' compensation claim, which was denied by Korner Store, contending that the fall was attributable to an idiopathic characteristic or was due to some unexplained, but not work related, cause. The trial court granted summary judgment in favor of Korner Store, but the Alabama Court of Civil Appeals reversed. The Supreme Court reversed the Court of Civil Appeals, finding that in order to be a compensable injury, causation requires the injury to be the result of an accident arising out of and in the course of employment. The Court went through a lengthy analysis of many cases, and specifically rejected a "but for" standard in determining whether an on the job injury is compensable under the workers compensation statute. Although "courts must liberally construe the workers' compensation law to effectuate its beneficent purposes... such a construction must be one that the language of the statute fairly and reasonably supports." SInce the statute allows for benefits only in the "case of personal injury or death...caused by an accident arising out of and in the course of [the employee's] employment", and Ms. Brown could not demonstrate what caused her fall, she was not entitled to workers compensation benefits.
