South Carolina high court grants comp benefits to worker who tripped on carpetPosted On: Jan. 15, 2015 12:00 AM CST
A South Carolina state employee who tripped and fell on the job should receive workers compensation benefits for her injuries even though the carpet she tripped on was not a unique condition of her employment, the South Carolina Supreme Court has ruled.
Carolyn M. Nicholson, a supervisor working for the child protective services department of the South Carolina Department of Social Services, fell at work in 2009 when her foot caught on a carpet in an office hallway, court records show. She filed for workers comp benefits related to pain in her neck, left shoulder and left side caused by the fall.
A commissioner of the South Carolina Workers' Compensation Commission denied benefits for Ms. Nicholson, finding that there was nothing specific about the floor at the social services department that caused her accident. However, records show the full workers comp commission reversed that decision, finding that Ms. Nicholson's fall arose out of her employment since it happened at work.
On appeal, the South Carolina Court of Appeals found that Ms. Nicholson's injuries weren't compensable because the carpet she tripped on “was not a hazard or special condition peculiar to her employment,” according to records. Therefore, the court said that her injuries did not arise out of her employment.
However, the South Carolina Supreme Court unanimously granted benefits to Ms. Nicholson on Wednesday. In its ruling, the court found that the appellate court “incorrectly focused on whether there was a specific hazard or danger unique to her employment that occasioned her fall.”
While South Carolina workers comp law has language saying that the cause of an occupational accident “must be peculiar to the work,” the high court said that section of the law is meant to establish that an injury is only compensable when directly connected to the workplace.
“In other words, but for the claimant being at work, the injury would not have occurred,” the ruling reads. “It does not require claimant to prove her injury is entirely unique to her employment, for any other interpretation would seriously undermine the law of workers' compensation. For example, a chef may cut himself with a knife, or a carpenter may fall off a ladder just as easily while at home rather than at work. However, this possibility alone does not remove such an accident from the scope of compensation if the accident occurred at work.”