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Headbutted prisoner ineligible for workers comp benefits: Wyoming high court


CHEYENNE, Wyo.—Wyoming's Supreme Court says a prison inmate is ineligible for workers compensation after another prisoner headbutted him during kitchen duty.

The assault at Wyoming State Penitentiary left Steven DeLoge with a broken nose. But the court said the injury is not compensable because it resulted from his assailant's illegal activity during an argument.

According to court records, Mr. DeLoge was working in the prison's kitchen when he told a supervisor that another had not properly cleaned a bread slicing machine. Soon after, Scott Bronson confronted Mr. DeLoge about his complaint, saying that the matter should have been handled without supervisor intervention.

In the midst of an expletive-laden exchange between the pair, Mr. Bronson headbutted Mr. DeLoge in the face. In testimony, Mr. Bronson said he was trying to make Mr. DeLoge move out of his way, though Mr. DeLoge did not touch or assault him.

Wyoming's workers comp law precludes prisoners from receiving compensation for injuries “resulting from any illegal activity” while in custody. In his appeal, Mr. DeLoge argued that his argument with Mr. Bronson was not illegal.

He also claimed in court records that the headbutt could have been unintentional, since Mr. Bronson did not “clarify whether or not the bump of heads occurred due to an intentional act of his own volition, an accident, or a sudden geologic shift in the surface of the earth which caused his head to contact (the appellant’s).”

The state supreme court disagreed, saying Mr. Bronson’s action should be interpreted as battery since it happened in the course of an argument.

“Bronson’s admission of his intent leaves little room for speculation as to the possible involvement of tectonic plate activity,” the court said. “This appeal borders on the frivolous.”