Bike v. Johnson & Johnson Health Care – Workers’ Comp Benefits in Spite of Underlying Injury

A man who suffered an injury at work caused by an underlying knee condition unrelated to his job will receive workers’ compensation, the Tennessee Supreme Court ruled.
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In Bike v. Johnson & Johnson Health Care Systems Inc., the worker was employed at a warehouse, and duties included wrapping pallets, packing boxes, loading trailers and making sure packing lists were accurate. One day in October 2009, he stepped onto a pallet in order to compare the pack list tags when his knee cap moved out of place, and then back. He fell to the floor.

The only injury he suffered was to his knee, and this was not caused by the fall, but rather by an unrelated, underlying condition. He received a myriad of treatments, including emergency treatment right after the incident, physical therapy, braces and activity restrictions. When conservative treatments were unsuccessful, employee proceeded with surgery.

Doctors opined worker had an anatomical predisposition for the kneecap issue, but the condition can be triggered when the knee is flexed. However, treating physician indicated there was nothing in particular about worker’s work environment that caused his knee cap to move out of and then back into place. Still, it was the movement worker made in stepping off the pallet – something he did routinely – that caused his knee cap to move out of place in that particular instance.

When the employee sought workers’ compensation benefits, his employer denied the claim, contending the injury was idiopathic and thus not compensable. A benefit review (similar to mediation) was not productive and the worker filed a civil lawsuit seeking relief.

Trial court ruled worker’s knee injury was due to an idiopathic condition, and because there was no special hazard in his working environment that contributed to the injury, the claim was not compensable.

Worker appealed, and the Tennessee Supreme Court reversed.

The primary question here was whether the injury arose out of employment. Court noted this occurs when there is some kind of a causal connection between the condition under which the work is required to be performed and the injury that resulted. True, it’s not enough that an employee was simply at work when an injury happened. But the worker argued his job required him routinely to step onto and off of the pallets, and that this was a special hazard of his job that resulted in his knee injury.

Meanwhile, his employer argued the knee injury was idiopathic.

Even so, the court noted that idiopathic injuries can be compensable if there is a work-related hazard that either causes or exacerbates the injury.

The worker was anatomically predisposed (according to his doctor) to the knee condition. Still, the fact that the worker was indisputably stepping off the pallet at the time of the injury and that this position (something he was required to do repeatedly in a given workday) was what caused the knee cap to move out of place, the court ruled the injury was in fact compensable.

If you have been injured at work, contact the Lee Law Offices at 800-887-1965.

Additional Resources:
Bike v. Johnson & Johnson Health Care Systems Inc., March 15, 2015, Tennessee Suprem Court

More Blog Entries
Shubert v. Macy’s West, Inc. – Failure to Adhere to Care Plan, March 19, 2015, Charlotte Workers’ Compensation Lawyer Blog

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