City of Virginia Beach v. Nora Hamel

CourtCourt of Appeals of Virginia
DecidedFebruary 26, 2019
Docket1531181
StatusUnpublished

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

Bluebook
City of Virginia Beach v. Nora Hamel, (Va. Ct. App. 2019).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Petty, Chafin and O’Brien Argued at Williamsburg, Virginia UNPUBLISHED

CITY OF VIRGINIA BEACH MEMORANDUM OPINION* BY v. Record No. 1531-18-1 JUDGE TERESA M. CHAFIN FEBRUARY 26, 2019 NORA HAMEL

FROM THE VIRGINIA WORKERS’ COMPENSATION COMMISSION

Kathleen Keffer, Assistant City Attorney (Mark D. Stiles, City Attorney; Christopher S. Boynton, Deputy City Attorney, on brief), for appellant.

No brief or argument for appellee.

The City of Virginia Beach (“the City”) appeals a decision of the Workers’

Compensation Commission awarding benefits to Nora Hamel for injuries sustained on August 1,

2016. On appeal, the City contends that the Commission erred by determining that Hamel’s

injuries arose out of her employment. For the following reasons, we reverse the Commission’s

decision.

I. BACKGROUND

On appeal from a decision of the Workers’ Compensation Commission, the evidence and

all reasonable inferences that may be drawn from that evidence are viewed in the light most

favorable to the party prevailing below. Clinchfield Coal Co. v. Reed, 40 Va. App. 69, 72

(2003). So viewed, the evidence establishes that on August 1, 2016, Hamel was employed by the

City as a licensed professional counselor in its Department of Human Services. As part of her

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. employment, Hamel was required to attend an off-site mandatory training at a community

college.

When Hamel arrived on campus, she parked her vehicle “really far” from the building

and asked for directions to the building in which the training was being held. As Hamel

approached the building, she stepped over a curb into a grassy area containing exposed tree

roots. Hamel tripped twice and fell over one of two raised tree roots and incurred injuries to her

face, head, right shoulder, right wrist, right hand, and cervical and lumbar regions. The tree roots

protruded approximately two inches above the ground. Hamel testified that she did not see the

tree roots before tripping.

Hamel filed applications seeking lifetime medical and temporary total disability benefits

from August 1, 2016 through December 16, 2016. The parties stipulated that if Hamel was

disabled as a result of the accident, she was entitled to temporary total disability benefits for that

time period.

During the March 15, 2017 hearing before the deputy commissioner, Hamel agreed that

she was not told where to park or assigned parking for the training. Further, she stated that there

were other available routes to the building in which the training was to be held and that there was

nothing defective about the sidewalk. The City contended that Hamel’s injuries did not arise out

of her employment because there was no causal connection between her work conditions and her

purported injuries.

In his May 16, 2017 decision, the deputy commissioner found that Hamel “failed to prove

by a preponderance of the evidence that her fall and resulting injuries arose out of a risk peculiar

to her employment.” The deputy commissioner went on to find that Hamel “failed to prove the

existence of a ‘critical link’ between her attendance at the mandatory training and the necessity

of traversing over the specific grassy area with raised roots that caused her to trip and fall.”

- 2 - Hamel requested review by the full Commission. She contended that proof of a “critical

link” between her attendance at the training and the way she walked to the building was

unnecessary as Virginia does not subscribe to the contributory negligence doctrine under the

Virginia Workers’ Compensation Act. Hamel claimed that she was required to cross the parking

lot to attend the mandatory training, and therefore, tripping over the root was a “risk of

employment” under the actual risk test.

On January 3, 2018, the full Commission reversed the deputy commissioner’s May 16,

2017 opinion. The Commission disagreed with the City’s contention that the “going and coming

rule” prevented Hamel’s injury from arising out of employment and applied the “special errand”

exception to Hamel’s incident, ruling that she did, in fact, suffer injuries in the course of her

employment. Because she was required to attend the off-premises training, Hamel was “in the

course of employment” until she returned to her regular workplace or home. The Commission

further rejected the City’s contention that “compensability necessitates a risk that is ‘unique’ to

the employment or is one to which the general public is not also exposed.” Hamel’s claim was

remanded to the deputy commissioner for further findings as to “the extent of the claimant’s

causally related injuries and her request for approval of additional medical treatment and

surgery.”

The deputy commissioner found on remand in his March 27, 2018 decision that Hamel

had, in fact, suffered compensable injuries to her right hand, right wrist, right shoulder, head, and

neck and that “all treatment represented in [Hamel’s medical records] . . . was reasonable,

necessary, and causally related to [her] August 1, 2016 fall.”

The City requested that the full Commission once again review its finding that Hamel’s

injuries arose out of her employment. The Commission declined to reconsider its January 3,

2018 opinion finding that “the exposed tree roots and uneven surface [Hamel] was walking

- 3 - across constituted a risk of employment, and caused injuries that arose out of her employment.”

The Commission affirmed the deputy commissioner’s March 27, 2018 decision.

The City now appeals to this Court.

II. ANALYSIS

On appeal, the City challenges the Commission’s decisions finding that Hamel’s injuries

arose out of her employment. Specifically, the City argues that Hamel failed to establish a causal

connection between a special risk to her employment with the City and her injury. For the

reasons that follow, we agree with the City’s position and reverse the Commission’s holding.

“The question of ‘[w]hether an accident arises out of the employment is a mixed question

of law and fact.’” Cleveland v. Food Lion L.L.C., 43 Va. App. 514, 518 (2004) (quoting Plumb

Rite Plumbing Serv. v. Barbour, 8 Va. App. 482, 483 (1989)). This Court is bound by the

Commission’s underlying factual findings if those findings are supported by credible evidence.

See Artis v. Ottenberg’s Bakers, Inc., 45 Va. App. 72, 83-84 (2005) (en banc). However, we

review de novo the Commission’s definitive decision with regard to whether the accident arose

out of Hamel’s employment with the City. See Caplan v. Bogard, 264 Va. 219, 225 (2002).

For an injury to be compensable under the Workers’ Compensation Act [(“Act”)], the claimant must prove by a preponderance of the evidence three elements: (1) that the injury was caused by an accident; (2) that the injury was sustained in the course of employment; and (3) that the injury arose out of the employment.

Snyder v. City of Richmond Police Dept., 62 Va. App. 405, 412 (2013) (quoting Southland Corp.

v. Parson, 1 Va. App. 281, 283-84 (1985)). “The concepts ‘arising out of” and ‘in the course of’

employment are not synonymous and both conditions must be proved before compensation will

be awarded.” Marketing Profiles, Inc. v. Hill, 17 Va. App. 431, 433 (1993) (en banc) (quoting

Bradshaw v. Aronovitch, 170 Va. 329, 335-36 (1938)).

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