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The children of an injured worker who died from an illegal drug overdose should receive lifetime workers compensation survivor benefits, even though their father's death was not work-related, a Missouri appellate court has ruled.
David Spradling was injured in 1998 while stacking and lifting pallets for Poplar Bluff, Mo.-based Smiley Container Corp., court records show. Mr. Spradling filed several amended and pending workers comp claims before he died of an “overdose of illegal drugs (that) was in no way related” to his work injury.
Representatives for Mr. Spradling's three dependent children filed a workers comp claim in 2008 seeking “all accumulated benefits” that would have been payable to Mr. Spradling, and subsequently his children after his death, records show. The children ultimately settled their claim with Smiley Container and the employer's workers comp insurer.
An administrative law judge awarded permanent total disability workers comp benefits to Mr. Spradling in 2011, records show. Because the award was based on a series of injuries, rather than his most recent work injury, the benefits were to be paid by Missouri's Second Injury Fund.
Because Missouri workers comp law requires lifetime benefits to be paid to surviving dependents of injured workers, the judge ordered that Mr. Spradling's children should receive $156 “in equal shares” per week for life, records show. Missouri's Labor and Industrial Relations Commission affirmed that decision, and the state Second Injury Fund filed an appeal.
The Second Injury Fund argued that Mr. Spradling's death was unrelated to his alleged work injury, that his children were residing with their mothers and were not dependent on him, and that Mr. Spradling had not sufficiently proven that he suffered from a work-related injury, records show.
A three-judge panel of the Missouri Court of Appeals unanimously affirmed the commission's ruling on Nov. 5. In its decision, the court found the commission considered Mr. Spradling's workers comp claim to be credible, and that his three children qualified as dependents eligible to receive comp benefits under Missouri law.
“There was competent and substantial evidence presented to prove the date of Spradling's injury and the medical expert testimony offered by dependents was sufficient to support the commission's award,” the ruling reads.
A deceased miner's spouse is not required to establish cause of death to receive benefits for black lung disease under the Patient Protection and Affordable Care Act, a U.S. appeals court ruled Thursday.