Rice v. AT & T

Summary

The plaintiff appealed a denial of workers' compensation benefits after she injured her back while performing routine work tasks. The Louisiana Court of Appeal reversed, holding that the incident qualified as an accident under the amended workers' compensation statute because it was a sudden, identifiable event producing objective injury, even though her back was weakened by a preexisting degenerative condition. On rehearing, the court removed the statutory penalty award because the employer reasonably controverted the claim.

Holdings

1. Where a worker suffers from a gradually deteriorating or progressively degenerative condition, the legislature did not intend to limit the definition of accident to only extraordinary exertions; a relatively minor occurrence that directly produces sudden objective findings of injury is an accident.
2. Statutory penalties should not be awarded when the employee's right to benefits was reasonably controverted by the employer.

Questions Presented

1. Whether the plaintiff suffered a compensable 'accident' under LSA-R.S. 23:1021(1) when a relatively minor, routine work movement directly produced objective injury against a background of a preexisting degenerative spinal condition.
2. Whether statutory penalties under LSA-R.S. 23:1201E should be awarded when the employer reasonably controverted the employee's right to benefits.

Disposition

reversed