Alexandria City Public Schools v. Handel

CourtSupreme Court of Virginia
DecidedOctober 15, 2020
Docket190957
StatusPublished

This text of Alexandria City Public Schools v. Handel (Alexandria City Public Schools v. Handel) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alexandria City Public Schools v. Handel, (Va. 2020).

Opinion

PRESENT: Lemons, C.J., Goodwyn, Mims, Powell, Kelsey, and McCullough, JJ., and Koontz, S.J.

ALEXANDRIA CITY PUBLIC SCHOOLS, ET AL. OPINION BY v. Record No. 190957 JUSTICE WILLIAM C. MIMS October 15, 2020 KERRI HANDEL

FROM THE COURT OF APPEALS OF VIRGINIA

In this appeal, we consider whether the Court of Appeals correctly defined and applied

the legal standard for determining whether a workers’ compensation claimant suffered a

compensable “injury by accident” to her shoulder. 1

I. BACKGROUND AND MATERIAL PROCEEDINGS BELOW

Kerri Handel was a math teacher at T.C. Williams High School in the City of Alexandria

when she slipped on a puddle on her classroom floor and fell on her right side. Alexandria City

Pub. Schs. v. Handel, 70 Va. App. 349, 352 (2019). She was taken by ambulance to the hospital

with multiple injuries, including “[p]ain in joint, shoulder region.” She later filed an injury

report with the school system listing injuries to her right ankle, knee, hip, shoulder, neck, and

back. Id. at 352-53. Only the shoulder is disputed here.

Handel consulted her first orthopedist within a week of the fall and again 29 months later.

He concluded that her shoulder pain was nerve related and referred her to another orthopedist for

a second opinion. The second orthopedist detected no abnormalities in the medical imaging of

Handel’s right shoulder, but she complained of pain radiating down her arm with numbness in

1 “Injury by accident” is a term of art used in the definitions of the Workers’ Compensation Act. Code § 65.2-101. her hand. This second orthopedist concluded she had a neurological condition in her shoulder

and referred her to physical therapy. Id. at 353.

Handel filed claims for an award of benefits by the Workers’ Compensation Commission.

At a hearing before a deputy commissioner, the school system disputed the claimed injury to

Handel’s shoulder. The deputy commissioner ruled that there was no dispute in the evidence

about how Handel had been injured, that there was a causal connection between the accident and

the shoulder complaints, and that Handel had suffered an “injury by accident” to her shoulder.

Id.

The school system appealed the deputy commissioner’s decision to the full commission,

asserting that the evidence was insufficient to establish a structural or mechanical change to the

shoulder, so Handel had not established that it was a compensable injury by accident. The

commission affirmed. Id. at 353-54. It found no error in the deputy commissioner’s factual

finding that Handel injured her shoulder in the fall and therefore was a compensable injury by

accident. It noted that Handel had

testified she “fell forward onto [her] right side.” Her right hip injury caused the most pain at the time. She began suffering headaches and dizziness thereafter. [She] completed an accident report. She wrote that she fell on her right side and affected her “right ankle, knee, hip, shoulder, neck, and back.” The pertinent medical record reflects that [Handel] received emergency medical attention . . . . Her diagnoses included “pain in joint, shoulder area.” Three x-ray views of her right shoulder revealed normal findings. When [she] received further neurological care, she reported suffering shoulder pain following the fall.

(Citations omitted.)

The commission then ruled that

[f]rom this evidence, we agree [Handel] established a compensable injury by accident to the right shoulder. [She] testified to falling on her right side and she reported symptoms to her initial health care providers. A diagnosis of shoulder

2 pain was rendered. No party designated medical records dated immediately prior to the accident regarding complaints of shoulder symptoms.

The school system appealed to the Court of Appeals asserting that the commission had

“erred, as a matter of law, in finding that the claimant suffered a compensable injury to her right

shoulder.”

The Court of Appeals first noted that to establish a compensable injury by accident, a

claimant must prove “‘(1) an identifiable accident; (2) that occurs at some reasonably definite

time; (3) an obvious sudden mechanical or structural change in the body; and (4) a causal

connection between the incident and the bodily change.’” 70 Va. App. at 354-55 (quoting

Hoffman v. Carter, 50 Va. App. 199, 212 (2007)). It then held that “a single ‘sudden mechanical

or structural change’ anywhere in the body suffices to establish that a claimant has suffered an

‘injury by accident.’” Thus, having established such a sudden or mechanical change anywhere,

any injury causally connected to the accident—even if not connected to the sudden or mechanical change—is compensable. In other words, a claimant does not need to prove a structural or mechanical change in every part affected by an obvious accident as long as there is at least one sudden or mechanical change and each injury is caused by the accident.

Id. at 355-56.

The court reasoned that the purpose of the “sudden mechanical or structural change”

element for determining whether an injury by accident has occurred is solely to exclude injuries

caused by gradual changes over time, such as (1) injuries arising from the regular and usual

exertions of the job, rather than any discrete accident or (2) injuries arising from the gradual

deterioration of a condition, which is not sudden. Id. at 356. It also noted that an injury by

accident may occur without proving a sudden mechanical or structural change if the claim is for

purely psychological injury and the claimant instead successfully establishes a sudden shock or

fright. Id. at 356-57.

3 Aggregating these three points, the court ruled that they underscored that the focus of the

“sudden mechanical or structural change” element was to establish suddenness—i.e., that an

accident had occurred—rather than mechanical or structural change. Id. at 357 (stating that “the

purpose of proving the ‘sudden mechanical or structural change’ is to establish the injuries are

accidental”), 358 (stating that the Court of Appeals “applies the ‘sudden mechanical or structural

change’ test as a threshold to establish the claimant has suffered an accident. Once the accident

is established, any injuries resulting from that accident, even if not connected directly to the

sudden mechanical or structural change, are compensable”), 359 (characterizing this Court’s

decision in Morris v. Morris, 238 Va. 578 (1989) as reversing an award of benefits “not because

the claimant had failed to demonstrate a mechanical or structural change, but because the change

was not ‘sudden’” and therefore not accidental. However, once a claimant establishes an

accident, “and suffers one sudden mechanical or structural change, all injuries flowing from the

accident—even if unconnected to the ‘mechanical or structural change’—are ‘injuries by

accident’ and compensable.”).

Accordingly, the Court of Appeals concluded that because Handel had proven a single

“sudden mechanical or structural change” anywhere in her body, she had established an injury by

accident, and her evidence that her shoulder injury was causally connected to the accident made

it compensable even if there was no proof that the shoulder injury was connected to the proven

mechanical or structural change. Id. at 361-62.

We awarded the school system this appeal.

II. ANALYSIS

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ghameshlouy v. Com.
689 S.E.2d 698 (Supreme Court of Virginia, 2010)
Estate of Parfitt v. Parfitt
672 S.E.2d 827 (Supreme Court of Virginia, 2009)
Com. v. Jackson
661 S.E.2d 810 (Supreme Court of Virginia, 2008)
Hoffman v. Carter
648 S.E.2d 318 (Court of Appeals of Virginia, 2007)
Morris v. Morris
385 S.E.2d 858 (Supreme Court of Virginia, 1989)
Olsten of Richmond v. Leftwich
336 S.E.2d 893 (Supreme Court of Virginia, 1985)
Virginia Electric & Power Co. v. Cogbill
288 S.E.2d 485 (Supreme Court of Virginia, 1982)
Virginia Electric & Power Co. v. Quann
87 S.E.2d 624 (Supreme Court of Virginia, 1955)
Snead v. Harbaugh
404 S.E.2d 53 (Supreme Court of Virginia, 1991)
Burlington Mills Corp. v. Hagood
13 S.E.2d 291 (Supreme Court of Virginia, 1941)

Cite This Page — Counsel Stack

Bluebook (online)
Alexandria City Public Schools v. Handel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alexandria-city-public-schools-v-handel-va-2020.