Georgia Appeals Court Reinstates Award for Teacher’s Fall in Classroom

In a recent case, a Georgia appeals court reinstated a teacher’s claim for Georgia workers’ compensation benefits after it was appealed for the third time. The teacher brought the claim for benefits after she injured herself at work. The teacher was instructing fifth grade at an elementary school and allegedly fell while walking from her desk to the front of the classroom, injuring her knee.Her employer argued the injury did not arise out of her employment. An administrative law judge for the State Board of Workers’ Compensation first granted the claimant’s claim for benefits, finding that she sustained an injury that arose out of and in the course of her employment. The board’s appellate division then reversed the lower court’s decision, denying her benefits. The appellate division found that the claimant’s injury was not compensable because it was not due to the configuration of the classroom, and the act of turning and walking was not unique to her employment. The court found that it was a risk to which she would have been equally exposed outside her employment, and it found it was caused by an idiopathic fall.

The claimant appealed, and the Superior Court then reversed the Board’s decision, reinstating the award. Finally, the employer appealed to the Georgia Court of Appeals.

The Court of Appeals of Georgia affirmed the lower court’s decision, allowing the claimant’s benefits award to stand. The court determined that her injury arose out of the claimant performing her duties as a classroom teacher and that the appellate division misapplied the legal term “idiopathic.”

The court explained that an injury arises out of employment when there is a causal connection between the conditions of the employment and the resulting injury. An injury generally is not compensable if the causative danger is not peculiar to the work in a way that connects the employment and the injury. That means that the activity or risk has to be “incidental to the character of the business.”

In this case, the appellate division found that the act of “turning and walking” was not a risk peculiar to her work, and she would have been equally exposed to the risk apart from her employment. However, in this case, the claimant was actively engaged in movements required of her as a classroom teacher when she was injured as a result of those movements.

Idiopathic Injuries

Under OCGA § 34-9-1 (4), for an injury to be compensable under the Workers’ Compensation Act, the injury must occur in the course of and out of the employment. An idiopathic injury is one that arises spontaneously or from an obscure or unknown cause. Injuries from idiopathic falls generally are not afforded benefits under the Workers’ Compensation Act because they do not arise out of employment. However, even in the case of an idiopathic fall, a claimant may be entitled to benefits—for example, if a claimant hits a workplace-related object during an idiopathic fall.

Contact a Georgia Workers’ Compensation Attorney

If you or a loved one has been injured at work, you may be entitled to workers’ compensation benefits. At the Georgia law office of J. Franklin Burns, P.C., we have a track record of positive case outcomes resulting in millions of dollars in compensation. Our Georgia workers’ compensation attorneys are former insurance defense attorneys, which means that we understand the other side’s tactics. This allows us to further our clients’ cases at trial or through settlement by using this inside knowledge and experience. For a free consultation, call the office of J. Franklin Burns, P.C. at 404-303-7770, or contact us through our online form.

More Blog Entries:

Court Denies Workers’ Compensation Benefits Due to Failure to Raise Issue During Initial Hearing, August 6, 2018, Atlanta Workers’ Compensation Lawyer Blog

Court Denies Benefits for Claimant Hit by Drunk Driver While Walking Back to Hotel, July 20, 2018, Atlanta Workers’ Compensation Lawyer Blog