Koprowski v. Baker et al – Workers’ Compensation for Prisoners?

In almost all states, workers’ compensation provides an exclusive remedy for employees injured on-the-job. What that means is workers cannot sue their employers for job-related injuries or illness; the only relief to which they are entitled from the employer is via workers’ compensation benefits. The trade-off is workers don’t have to prove the company was at-fault, and benefits are supposed to be provided faster. prison1

But what if the worker injured was an incarcerated federal inmate?

These individuals do still have rights (although they are limited) and their work-related injuries are covered under the Inmate Accident Compensation Act, which sets forth procedures for payment of accident compensation resulting from work-related injuries to federal prison inmates or their dependents.   

As the recent case of Koprowski v. Baker shows, workers under this system may not be beholden to the exact same rules as those under the typical workers’ compensation system in North Carolina.

According to court records, plaintiff was an inmate a federal correctional facility in 2009 when, while carrying out cleaning duties, he fell after stepping off a ladder and hurt his back. For a few minutes, his legs had no feeling. He tried to stand up and was in excruciating pain. He had trouble walking for several days and overwhelming pain consumed him even when he tried to lay down.

Medical staff at the prison, he alleged, treated his injury as insignificant, and acted as if he was malingering. This resulted in unnecessary pain and aggravation of his condition. There was a delay in taking x-rays and a refusal to perform an MRI scan – which would have shown he had broken his back. He alleges he was denied special care, surgery and pain medications. He said at one point, he was threatened with solitary confinement if he refused to give up the wheelchair he’d been using. This resulted in his being bedridden. He was another time sent to the “hole” (solitary confinement) for not being able to walk to his prison job.

A full week after the injury, he finally was allowed an x-ray, where the fracture was revealed. The condition worsened, and has since resulted in lifelong disability and chronic pain.

He was eligible to receive benefits through the compensation act, which he did. However, he also filed a “Bivens lawsuit” against a half dozen prison officials, alleging they had violated his Eighth Amendment rights by acting with deliberate indifference to his serious medical needs.

The district court dismissed claimant’s lawsuit, finding the IACA was the sole avenue for recovery of compensation by a federal inmate who suffered injuries during the course of prison employment. However, the U.S. Court of Appeals for the Sixth Circuit reversed.

The court noted that the IACA is not intended to limit or exclude a prisoner’s ability to seek damages from officials in prison for alleged constitutional violations, such as the one claimed here. The court looked to three other sister courts that had decided the same issue, each concluding that the act does not displace a prisoner’s ability to file a claim of constitutional wrongs. Just because the underlying injury occurred in a prison work context does not mean the subsequent alleged actions of prison officials are not actionable.

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

Additional Resources:

Koprowski v. Baker , May 11, 2016, U.S. Court of Appeals for the Sixth Circuit

More Blog Entries:

Report: Poultry Industry Workers Denied Bathroom Breaks, Forced to Wear Diapers, May 8, 2016, Charlotte Workers’ Compensation Lawyer Blog

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