D & E Investments, L.L.C. v. Singleton

Summary

The Alabama Supreme Court reviewed whether an employee’s oral statement that he injured his back while “emptying the trash can,” combined with his supervisor’s knowledge of the employee’s job duties, provided sufficient notice of a work-related injury under the Alabama Workers’ Compensation Act. The court held that the information was sufficient to put a reasonable supervisor on inquiry and that the trial court’s finding should not have been reversed. The court reversed the Court of Civil Appeals’ judgment and remanded the case.

Holdings

1. An employee's statement that he injured his back while “emptying the trash can,” coupled with the supervisor's knowledge that emptying a fifty-five-gallon trash can was part of the employee's job duties, constituted adequate notice sufficient to put a reasonable person on inquiry that the injury was work related.
2. When the facts are undisputed but reasonable persons could draw different conclusions about whether notice was sufficient, the appellate court may not substitute its judgment for the trial court's conclusion.

Questions Presented

1. Whether Singleton's statement that he injured his back while “emptying the trash can,” together with the supervisor's knowledge that emptying a fifty-five-gallon trash can was part of Singleton's job duties, constituted adequate actual notice of a work-related injury under Alabama Code § 25-5-78.
2. Whether the Court of Civil Appeals improperly substituted its judgment for the trial court's determination that the undisputed notice-related facts were sufficient to put a reasonable person on inquiry.

Disposition

reversed_and_remanded