A claims adjuster cannot receive workers compensation benefits for a head injury he mysteriously suffered while on a Texas beach because he was intoxicated at the time of his accident, a Washington state appeals court has ruled.
Rudolph Knight was a Seattle-based catastrophic claims adjuster for State Farm Mutual Automobile Insurance Co., court records show. He was assigned in 2008 to work on assignment in Galveston, Texas after the area was hit by Hurricane Ike.
On a day Mr. Knight wasn't scheduled to work, he drove 30 miles from his hotel to Galveston Island to survey hurricane damage, according to records. While driving to the hotel, he saw a group of men riding dune buggies on a beach and stopped to watch them. That was the last memory Mr. Knight had before his wife visited him in a Texas hospital 24 hours later.
Mr. Knight's wife spoke to him by phone while he was watching the dune buggy riders, and she heard the men approach him, records show. A few hours later, paramedics responded to a 911 call and found Mr. Knight lying in the surf while mumbling “help me.”
Mr. Knight had small lacerations and some bruising, and was treated for hypothermia and intoxication, records show. Mr. Knight told paramedics that he had not used drugs, but that he “had a lot of alcohol to drink.”
Police and doctors noted that Mr. Knight smelled of alcohol after he was found, records show. Police did not determine how Mr. Knight was injured and did not take any witness statements on the beach where Mr. Knight was found.
A CT scan performed that day showed that Mr. Knight suffered a subarachnoid hemorrhage in his brain, according to court records. A hospital physician determined that Mr. Knight suffered a blunt trauma to his head that could have happened by falling on sand, and was not consistent with injuries caused by a punch to the head.
Mr. Knight's cognitive condition worsened while he was in the hospital, and he developed a wandering eye, which could have been caused by an angiogram performed by the hospital, records show. He filed for workers comp benefits since he was on assignment for Bloomington, Ill.-based State Farm at the time of his accident.
The Washington Board of Industrial Insurance Appeals denied Mr. Knight's claim, finding that he was injured because he became intoxicated, collapsed on the beach and hit his head on the sand, records show. Washington's King County Superior Court upheld that ruling, finding that Mr. Knight abandoned his employment when he drove to the beach and drank until he was intoxicated.
A three-judge panel of the Washington Court of Appeals unanimously upheld the lower court rulings Monday, finding that Mr. Knight abandoned his employment when he drank to intoxication. Therefore, the ruling reads, Mr. Knight's injuries occurred outside of the scope of his employment.
“Knight argues that his decision to stop on the beach and watch the dune buggy riders was an activity within the personal comfort doctrine and did not take him outside of the scope of employment,” the ruling reads. “Even if we accept this premise, becoming intoxicated is beyond the personal comfort doctrine, and Knight did not meet his burden on summary judgment to show that his injury occurred before he became intoxicated.”
Mr. Knight argued in court filings that “a jury could reasonably find that Mr. Knight was the victim of a crime or accident” or that “he did not purposefully drink at all or at the very least did not drink to the point of abandonment.” However, the appellate court dismissed that argument as “pure speculation” since there is no evidence of what happened to Mr. Knight between the time he spoke with his wife and when he was found on the beach.