Injury at work hardening program not directly caused by first injury
Case name: Washington Metropolitan Area Transit Authority v. Williams, No. 2316, September Term, 2010 (Md. Ct. Spec. App. 04/26/12).
Ruling: The Maryland Court of Special Appeals held that there was not a sufficient causal connection between a worker's first injury and second injury that occurred during a lunch break at a work hardening program to award compensation.
What it means: In Maryland, to receive compensation for a second injury, there must be a "direct causal connection" between the original injury and the subsequent injury.
Summary: A mechanic for a transit authority injured his back and left knee while working. He participated in a work hardening program. He walked to his truck during his lunch break. When he finished eating, he walked through the parking lot to return to another session of the work hardening program. The mechanic was struck by a car in the parking lot, knocking him to the ground. The mechanic injured his right knee and sought workers' compensation benefits. The Maryland Court of Special Appeals held that there was not a sufficient causal connection between the first injury and the second injury to award compensation. However, the court sent the claim back to the Workers' Compensation Commission for a determination of whether the second injury, standing alone, occurred in the course of employment.
The court concluded that the second injury did not directly result from the first injury. The second injury was caused by the driver of the car who hit him in the parking lot. The court explained that the negligent actions of the driver were not connected to the first injury except that the first injury placed the mechanic in the parking lot.
The court rejected a contention that the requirement that the transit authority pay for the medical treatment for the mechanic's first injury sufficiently connected the work hardening treatment to the employment to create a "direct causal connection."
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July 9, 2012
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