Court of Appeals Provides Clarity to Idiopathic Injury Cases

The Court of Appeals has recently issued its decision in Chambers v. Monroe County Board of Commissioners, 2014 Ga. App. LEXIS 551 (2014), providing some clarity in the murky area surrounding idiopathic injuries. The claimant in Chamberswas a firefighter/EMT for Monroe County. The claimant was asked by a supervisor to stand from her chair when she heard a pop in her left knee, resulting in knee surgery, and likely an eventual knee replacement. The claimant testified that she did not get up from her chair in an unusual manner and offered no testimony to establish any causal connection between her employment and her injury.

The Court of Appeals found that there was some evidence to support the Board’s determination that the injury had no causal connection to the employment as there was no evidence that the employee slipped, tripped, or fell or came into contact with any object or hazard that increased her risk of injury, but that she simply rose from a seated position. It therefore was not compensable.

It has been repeatedly held that where there is any competent evidence to sustain a finding by the Board, such finding is conclusive and binding on a reviewing court. It is for this reason that factually similar cases  can have differing results. For example, Harris v. Peach County Bd. of Comm’rs, 296 Ga. App. 225 (2009), found that a knee injury sustained while bending to pick something up was compensable. However, the idiopathic knee injuries sustained in Chaparral Boats, Inc. v. Heath, 269 Ga. App. 339 (2004) (injury sustained while walking quickly through employer’s parking lot), St. Joseph’s Hospital v. Ward, 300 Ga. App. 845 (2009) (injury sustained while turning to give a patient water), and Chambers (injury sustained when rising from a chair), were all found to be not compensable.

A surface analysis of these cases would lead one to think that they should all have the same outcome. Why then, did the courts find Harriscompensable, but Chaparral Boats, Ward, and Chambers not? The reasoning is that all four cases are consistent in holding that the superior courts, and Court of Appeals, may not substitute their judgment for that of the Board on the question of whether an injury arose out of the claimant’s employment. While the law on idiopathic injuries remains slightly cloudy, we are provided with three main takeaways from these cases. First, as stated above, the Court of Appeals is unlikely to disturb the findings of the State Board’s Appellate Division. The Court of Appeals stated in clear language that the State Board, as the fact-finder, must in each case remain the final arbiter of whether the claimant’s disability arose out of the employment, and the Court of Appeals recognized that it must abide by those conclusions. Second, these cases reiterate that idiopathic injury cases are extremely fact-sensitive. It can be difficult to determine which facts are critical and which are not, based on the above outcomes. However, Chaparral Boatsremains intact and provides the framework for deciding these cases. Finally, we know that the State Board will always look at whether the injury-causing activity was done in furtherance of the claimant’s job, in conjunction with an injury-causing risk to which the claimant would not be equally exposed to outside of employment. Fortunately, simply standing up, although at a supervisors request, somehow causing a knee injury is not compensable.

Written by: Ariel I. Adams