Harris v. Board of Education of Howard County, 375 Md. 21

Summary

The Maryland Court of Appeals held that the Workers’ Compensation Act does not require a compensable accidental injury to result from unusual activity. The court overruled prior Maryland decisions imposing that requirement and concluded that the injury, rather than the activity causing it, must be accidental and arise out of and in the course of employment. The court reversed the judgment against Vernell Harris and did not reach whether her activity was unusual.

Holdings

1. The Maryland Workers' Compensation Act does not require that an accidental personal injury result from unusual activity, strain, exertion, or an unusual condition of employment. The injury, rather than the activity causing it, must be accidental; the activity need only arise out of and occur in the course of employment and not be otherwise excluded by the Act.
2. Harris sustained a compensable accidental personal injury arising out of and in the course of her employment because her back injury was an unexpected and unintended result of employment-related work.
3. The Court overruled Slacum v. Jolley, Miskowiak v. Bethlehem Steel Co., Atlantic Coast Shipping Co. v. Stasiak, and similar decisions to the extent they required an accidental injury to arise from unusual activity or conditions to be compensable.

Questions Presented

1. Whether an accidental personal injury under the Maryland Workers' Compensation Act must result from unusual activity, strain, exertion, or a condition of employment to be compensable.
2. Whether Harris's back injury, arising from routine employment-related activities and occurring unexpectedly and unintentionally, was a compensable accidental personal injury under the Act.
3. Whether the Court should overrule Maryland decisions that had added an unusual-activity requirement to the statutory definition of accidental injury.

Disposition

reversed_and_remanded