Court Holds Subsequent Injury Was a Direct and Natural Consequence of Primary Work-Related Injury
Enterprise Leasing Company – South Central, LLC v. Drake
In this matter, a driver for Enterprise Leasing Company – South Central, LLC (“Enterprise”), filed a verified Complaint against Enterprise for a left-knee injury he sustained after exiting one of Enterprise’s vehicles in August 2015. The employee also included a claim for a right-knee injury he sustained four months after his incident at work, alleging he suffered the right-knee injury due to the left-knee injury.
At trial, the employee admitted he had been involved in a previous automobile crash in 2012 and that he experienced pain in his right knee after the crash. There were also medical records showing the employee had degenerative joint disease in his knees which altered his gait. Yet, he continued to work for Enterprise without any restrictions or limitations before the 2015 work-related incident. In addition, the employee, who was eighty-one years old, offered testimony from his physician that “it was not uncommon, particularly for someone of the employee’s age, to begin complaining about a joint on one side of the body following an injury to the corresponding joint on the other side of the body.” The trial court ruled in favor of the employee after finding he presented clear and convincing evidence that his right-knee injury was a direct and natural consequence of his work-related left-knee injury.
On appeal, Enterprise argued the employee failed to present clear and convincing evidence that his right-knee injury was compensable. However, in its analysis, the Alabama Court of Civil Appeals emphasized that the issue was whether the right-knee injury was related to the left-knee injury rather than compensability. Accordingly, the Court held that under Alabama law “[w]hen the primary injury is shown to have arisen out of and in the course of employment, every natural consequence that flows from the injury likewise arises out of the employment, unless it is the result of an independent intervening cause attributable to [the] claimant’s own intentional conduct.” Notwithstanding evidence regarding the 2012 automobile crash and the medical records showing the employee’s right knee pain pre-existed the 2015 work-related incident, the Court affirmed the trial court’s holding that the right-knee injury was related to the left-knee injury.
