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The Supreme Court of Alabama's clarification of causation pursuant to the Alabama Workers' Compensation Act

In a recent decision by the Supreme Court of Alabama, the Court specifically addressed the causation issue in the context of a worker's compensation claim. Ex parte Patsy Patton d/b/a Korner Store, 1080960 (Ala. 2011). In Patton, the Supreme Court of Alabama considered the appeal of Lana Brown following the trial court's summary judgment in favor of her employer regarding her worker's compensation claims. Id. Pertinent facts included that plaintiff worked as a cashier for the defendant's gas station/convenience store. Id. While on duty, plaintiff filled her coffee cup and began to walk back to her work area when she fell, breaking her wrist. Id. Plaintiff's employer contended that plaintiff's fall was either attributable to an idiopathic characteristic or was due to an unexplained, but not work related, cause. Id. Following the Supreme Court of Alabama's recent decision in Ex parte Byrom, 895 So. 2d 942 (Ala. 2004), the Alabama Court of Civil Appeals reversed the trial court concluding that substantial evidence was presented establishing that the accident arose out of the plaintiff's employment. Id.

In reversing the Alabama Court of Civil Appeals, the Alabama Supreme Court provided a thorough analysis of the development of the rule of causation in worker's compensation cases. The Court recognized that the "but for" language set forth in the Court's opinion in Byrom conflicted with prior case law regarding causation in worker's compensation law. Specifically, the Alabama Supreme Court recognized that the Alabama Court of Civil Appeals' determination that "Byrom eliminates any requirement that might have been applied in WalMart Stores, Inc. v. Morgan, 830 So. 2d 741 (Ala. Civ. App. 1981), to require an employee who falls at work, such as the employee in this case, to show legal causation beyond the fall itself." Id. The Patton court concluded that although it had construed the Worker's Compensation Act to achieve its "beneficent purposes," the Act provided worker's compensation benefits only in "cases of personal injury or death . . . caused by an accident arising out of and in the course of the employee's employment . . .". Id. citing '25-5-51 Alabama Code (1975). Concluding that the Court of Civil Appeals had applied a rule of causation that contravened the clear language of the Alabama Worker's Compensation Act, the Supreme Court of Alabama reversed the Court of Civil Appeals and rendered judgment in favor of the employer.

Unquestionably, this is a significant decision for every worker's compensation case in analyzing whether the employee's injury was caused by an accident arising out of and in the course of the employment.

Contributing Author:

James W. Moss
James W. Moss, Shareholder
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