Rieger v. Washington Suburban Sanitary Commission, 211 Md. 214

Summary

The Maryland Court of Appeals held that a back injury sustained by a pipe fitter while performing routine work was not an accidental injury compensable under the Maryland Workers’ Compensation Act. Because the injury resulted from a normal position and exertion, rather than an unusual strain, exertion, or employment condition, the court affirmed dismissal of the compensation claim.

Holdings

1. An injury is accidental under Maryland workers' compensation law only when it results from some unusual strain or exertion or from some unusual condition in the employment; the claimant's evidence did not satisfy that standard.

Questions Presented

1. Whether the claimant presented legally sufficient evidence that his back injury was accidental and therefore compensable under the Maryland Compensation Act.
2. Whether an injury resulting from a normal position and ordinary exertion in the employment constitutes an accidental injury under Maryland workers' compensation law.

Disposition

affirmed