Aldridge v. Novant Health

CourtCourt of Appeals of North Carolina
DecidedDecember 7, 2021
Docket21-70
StatusPublished

This text of Aldridge v. Novant Health (Aldridge v. Novant Health) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aldridge v. Novant Health, (N.C. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2021-NCCOA-651

No. COA21-70

Filed 7 December 2021

North Carolina Industrial Commission, IC No. 18-018836

JENNIFER ALDRIDGE, Employee, Plaintiff

v.

NOVANT HEALTH, INC., Employer (Self-Insured), Defendant

Appeal by Defendant from an Opinion and Award entered 30 September 2020

by the North Carolina Industrial Commission. Heard in the Court of Appeals 20

October 2021.

Campbell & Associates, by Bradley H. Smith, for plaintiff-appellee.

Jason P. Burton for defendant-appellant.

HAMPSON, Judge.

Factual and Procedural Background

¶1 Novant Health, Inc., (Defendant) appeals from an Opinion and Award entered

by the Full Commission (Commission) of the North Carolina Industrial Commission

concluding Jennifer Aldridge (Plaintiff) suffered an injury by accident and granting

Plaintiff’s claim for compensation under the Workers’ Compensation Act. The Record

reflects the following: ALDRIDGE V. NOVANT HEALTH, INC.

Opinion of the Court

¶2 Plaintiff began working as a registered nurse for Defendant in November 2010.

Plaintiff worked at “Stanback Rehabilitation” unit in Rowan Hospital in Salisbury,

North Carolina. On 7 March 2018, Plaintiff was assigned to work on the “med-surg

unit”—not her usually assigned unit. On that day, Kayla Beeker (Beeker) a certified

nursing assistant (CNA), asked Plaintiff to assist Beeker in changing a pad

underneath a patient who had soiled herself. The patient was “very large” weighing

between 300 and 400 pounds. While Beeker stood on one side of the patient and

pulled the patient’s hip toward Beeker, Plaintiff stood on the other side and pushed

the patient’s hip with Plaintiff’s left hand and pulled on the soiled pad with her right

hand.

¶3 As Plaintiff pulled the pad, she heard a “snapping sound” and felt “a very sharp

pain and burning sensation that went from [her] wrist to [her] elbow” and to her

shoulder, neck, and back. Plaintiff had to pull with more force than usual because of

the patient’s size. Moreover, the patient did not help as Plaintiff tried to pull the pad

from under the patient. Plaintiff sought medical treatment, including surgery, as a

result of her injury. Plaintiff filed a Notice of Accident with Defendant. Defendant

denied Plaintiff’s workers’ compensation claim on the basis that Plaintiff’s injury was

“not the result of an accident or sudden traumatic event.”

¶4 On 31 July 2018, Plaintiff filed a request for a hearing with the Industrial

Commission on her compensation claim. Plaintiff’s compensation claim came on for ALDRIDGE V. NOVANT HEALTH, INC.

hearing on 17 January 2019 before a Deputy Commissioner. The Deputy

Commissioner heard testimony from both Plaintiff’s and Defendant’s witnesses. In

addition to the factual circumstances leading to Plaintiff’s injury, Plaintiff testified

that when she changes a patient’s pad, the patient typically pulls themselves up on

the side of the bed so that Plaintiff can roll the patient to the right and remove the

pad. According to Plaintiff, the patient in this instance “wasn’t helping . . . at all.”

When Plaintiff assisted with moving a patient who weighed as much as the patient

in the incident in question, Plaintiff would always be part of a team of at least three

people moving the patient. Plaintiff estimated she moved a patient of that size twice

a month as part of a team of three to four people. Plaintiff also stated she would help

others move patients “once a shift” on any given floor of the hospital and that “one

out of five” patients were overweight.

¶5 Beeker testified as Defendant’s witness. Although Beeker could not recall how

much the patient in this case weighed, she described the patient as “pretty hefty, but

it’s not uncommon for two of us to be turning a patient that is overweight and not

willing to help.” However, Beeker explained when a patient is “extremely obese or

they’re a difficult patient that we’ve already tried once to move . . . we’ll call for extra

help and a lot of times it’s maybe three of us, maybe four at the most.” Beeker also

stated she would have preferred to have three or four people moving the patient she

and Plaintiff moved on the day in question. She had also never witnessed Plaintiff ALDRIDGE V. NOVANT HEALTH, INC.

attempt to move a patient weighing approximately 350 pounds with only one other

person helping in the time Beeker had worked with Plaintiff.

¶6 Victoria Tuttle (Tuttle) testified on Plaintiff’s behalf. Tuttle was employed by

Defendant as a CNA at Rowan Hospital and worked with Plaintiff once or twice a

month at the time. Tuttle testified she had to move patients weighing 350 pounds to

change their pads as part of her duties with Defendant; but, when she did, “[t]hree to

four” people would assist and “[s]ix would be great if they’re noncompliant or they

can’t help themselves.” Tuttle stated she had previously tried to move a patient

weighing 350 pounds with only one other person assisting but could not do it, and she

had to get more help.

¶7 Christopher Cook (Cook) testified on Defendant’s behalf. Cook testified he was

employed as a nurse manager for Defendant at Rowan Hospital on the date in

question. According to Cook, nurses and nursing assistants would change pads on

patients every day and that he noticed a “trend in the population of obesity [in

patients] increasing[.]” Cook testified multiple nurses would work together in teams

to move overweight patients “daily.” However, Cook was not aware of an official

policy or protocol directing nurses or nursing assistants on how many employees

should assist in moving patients based on a patient’s weight and size. Cook also

stated that teams of at least three employees were needed to move patients on a “daily

basis[.]” ALDRIDGE V. NOVANT HEALTH, INC.

¶8 On 16 October 2019, the Deputy Commissioner entered an Opinion and Award

in Plaintiff’s favor. Based on the testimony, exhibits, and depositions filed in the

claim, the Deputy Commissioner made the following pertinent Findings of Fact:

5. In an attempt to change the soiled bed pad, CNA Beeker pulled the patient towards herself, and Plaintiff pushed from the opposite side of the bed, while also pulling on the bed pad with her right arm. The patient did not assist in moving herself. As she was pulling on the bed pad, Plaintiff heard a snap and felt sharp pain and a burning sensation in her right arm. Plaintiff immediately stopped and indicated to CNA Beeker that she had injured herself. . . .

....

7. It was not unusual for Plaintiff to be asked to work a different unit; this occurred approximately two to three times per month. In general, it was not unusual for a CNA to ask Plaintiff for help; this occurred regularly. It was also not unusual for Plaintiff to pull a bed pad out from under a patient; she estimated she performed this specific task twice per month.

9. It was also not uncommon for patients to be unable or unwilling to help when being moved; this could be due to dementia, being sedated, or being post-surgical.

10. Prior to March 7, 2018, Plaintiff had assisted in moving large patients before, but only as a team of three or four people. Plaintiff estimated she assisted in this fashion approximately twice per month.

11.

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Aldridge v. Novant Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aldridge-v-novant-health-ncctapp-2021.