Clint Ashworth v. Big Easy Foods of Louisiana, Inc.

CourtLouisiana Court of Appeal
DecidedDecember 11, 2013
DocketWCA-0013-0650
StatusUnknown

This text of Clint Ashworth v. Big Easy Foods of Louisiana, Inc. (Clint Ashworth v. Big Easy Foods of Louisiana, Inc.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clint Ashworth v. Big Easy Foods of Louisiana, Inc., (La. Ct. App. 2013).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

13-650

CLINT ASHWORTH

VERSUS

BIG EASY FOODS OF LOUISIANA, LLC, ET AL.

**********

APPEAL FROM THE OFFICE OF WORKERS’ COMPENSATION - # 3 PARISH OF CALCASIEU, NO. 12-02105 SAM L. LOWERY, WORKERS’ COMPENSATION JUDGE

ULYSSES GENE THIBODEAUX CHIEF JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, Marc T. Amy, and J. David Painter, Judges.

AFFIRMED.

Gregory Paul Allen Marceaux Marceaux Law Firm 2901 Hodges Street Lake Charles, LA 70601 Telephone: (337) 310-2233 COUNSEL FOR: Plaintiff/Appellee – Clint Ashworth

Azelie Ziegler Shelby Shelby Law Firm 3070 Teddy Drive Baton Rouge, LA 70809 Telephone: (225) 223-6961 COUNSEL FOR: Defendants/Appellants - LUBA Casualty Insurance Company, Inc. and Big Easy Foods of Louisiana, LLC THIBODEAUX, Chief Judge.

Clint Ashworth filed a workers’ compensation claim against his

employer, Big Easy Foods of Louisiana, LLC, and its insurer, LUBA Casualty

Insurance Company (collectively, “Big Easy”), after he severed the tip of his finger

while cleaning a meat grinder. Though Big Easy initially paid for and approved

benefits for Mr. Ashworth, the company later terminated benefits and alleged that

Mr. Ashworth had intentionally injured himself. Following a trial, the workers’

compensation judge (WCJ) entered judgment in favor of Mr. Ashworth, awarding

past medical expenses, indemnity benefits, penalties, and attorney fees.

Big Easy appeals. For the following reasons, we affirm the judgment.

I. ISSUES

We must determine whether the trial court:

(1) applied a higher evidentiary standard on Big Easy’s burden of proving an intentional injury;

(2) erred in finding that Big Easy did not prove that Mr. Ashworth committed an intentional injury;

(3) erred in finding that Big Easy was arbitrary and capricious in terminating Mr. Ashworth’s benefits; and

(4) erred in the amount of penalties and attorney fees awarded.

II.

FACTS AND PROCEDURAL HISTORY

Mr. Ashworth was employed at Big Easy−a sausage making

company. His duties included grinding meat and cleaning the equipment after each use. At the start of his employment, Mr. Ashworth received two days of on-the-job

training. As part of the training, Mr. Ashworth was taught how to clear the end

plate of the grinder of excess meat and place that meat into a container. Big Easy

instructed Mr. Ashworth to wipe off the excess meat with his bare hands.

Approximately one week after beginning work with Big Easy, Mr.

Ashworth was injured at work. After completing the grinding process with a

section of meat, Mr. Ashworth allegedly turned off the meat grinder. He then

attempted to clean the end plate of the grinder of excess meat. During the cleaning

process, the blades of the meat grinder severed the tip of Mr. Ashworth’s left index

finger.

Following the incident, Mr. Ashworth’s co-worker transported him to

the hospital where a surgeon performed a partial amputation of Mr. Ashworth’s

index finger. Doctors deemed Mr. Ashworth temporarily and totally disabled from

February 9, 2012 to April 30, 2012. His indemnity benefits began on February 17,

2012. Additionally, Big Easy initially paid for and approved medical benefits for

him. On March 15, 2012, however, Big Easy terminated payment of all medical

and indemnity benefits. Big Easy informed Mr. Ashworth that it believed he

intentionally injured himself. Mr. Ashworth denied Big Easy’s accusations and

filed suit.

Following a trial, the WCJ entered judgment in favor of Mr.

Ashworth, finding that he did not intentionally injure himself. The WCJ awarded

past medical benefits, penalties in the amount of $8,000.00 for arbitrary

termination of benefits and penalties in the amount of $2,000.00 for Big Easy’s

failure to pay the first week of indemnity benefits. He also awarded $17,768.25 in

attorney fees.

2 III. LAW AND DISCUSSION Standard of Review

The standard of review by the appellate court of findings of fact by

the WCJ is to determine whether the WCJ committed manifest error or was clearly

wrong. Metoyer v. Roy O. Martin, Inc., 03-1540 (La.App. 3 Cir. 12/1/04), 895

So.2d 552, writ denied, 05-1027 (La. 6/3/05), 903 So.2d 467; Wiley v. Grand

Casino Avoyelles, 98-1468 (La.App. 3 Cir. 4/21/99), 731 So.2d 518, writ denied,

99-2032 (La. 11/5/99), 750 So.2d 180. As long as the record supports the findings

of fact of the WCJ, and these findings of fact are reasonable, then an appellate

court cannot overturn those findings of fact. Metoyer, 895 So.2d 552.

Standard of Proof of an Intentional Injury

Big Easy contends that the WCJ committed legal error and placed a

higher burden of proof on it than the law requires. Specifically, Big Easy asserts

that the Louisiana Workers’ Compensation Act requires defendants to prove the

affirmative defense of intentional injury by a preponderance of the evidence but

that the WCJ committed legal error by requiring it to introduce direct and medical

evidence to prove its claim. While we agree with Big Easy as to the appropriate

standard of review, we disagree with its assertion that the WCJ legally erred and

held it to a higher standard.

Indeed, Big Easy is correct in stating that the burden of proving an

intentional injury in a workers’ compensation case is the normal burden of proof in

civil cases−a preponderance of the evidence. Brunet v. State of Louisiana, 442

So.2d 638 (La.App. 1 Cir. 1983). Big Easy is incorrect, however, in its assertion

3 that the WCJ held it to a higher standard than the law requires. In his oral reasons,

the WCJ correctly set forth the burden of proof placed on Big Easy for the

affirmative defense that Mr. Ashworth intentionally injured himself. As stated by

the WCJ: “So, the basic question to be answered in this litigation is whether the

defense can prove by a preponderance of the evidence that Mr. Ashworth

formulated the willful intent to mutilate himself.” He then proceeded to

exhaustively discuss the circumstantial evidence presented by Big Easy. The one

phrase uttered by the WCJ that Big Easy embraces in support of its argument is the

WCJ’s statement that the employer’s decision was “based purely on speculation

and suspicion and had no medical foundation whatsoever.”

Big Easy urges us to ignore the totality of the WCJ’s reasons and

instead find that his utterance of the words “medical foundation” indicates that the

WCJ applied the wrong legal standard. Thus, a de novo review is required. We

decline to do so. It is clear that the WCJ possessed a firm grasp of the legal

standard and of the evidence. The WCJ’s reference to the lack of a “medical

foundation” was only one of the factors that the WCJ considered in its overall

judgment in the case. Thus, we find no merit in Big Easy’s argument that the WCJ

applied the wrong legal standard to the case.

Defendants’ Lack of Proof of an Intentional Injury

Big Easy also contends that the WCJ erred in finding that it did not

meet its burden of proving that Mr. Ashworth intentionally severed his finger. We

find no merit in its argument and find that the WCJ was not manifestly erroneous

in awarding judgment to Mr. Ashworth.

4 Louisiana law provides that no compensation is owed to an employee

who intentionally injures himself. La.R.S. 23:1081(1)(a). An employer bears the

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Related

Williams v. Tioga Manor Nursing Home
24 So. 3d 970 (Louisiana Court of Appeal, 2009)
Metoyer v. Roy O. Martin, Inc.
895 So. 2d 552 (Louisiana Court of Appeal, 2005)
King v. Grand Cove Nursing Home
640 So. 2d 348 (Louisiana Court of Appeal, 1994)
Wiley v. Grand Casino Avoyelles
731 So. 2d 518 (Louisiana Court of Appeal, 1999)
Molinari v. Thompson, 2010-0253 (La. 4/9/10)
31 So. 3d 389 (Supreme Court of Louisiana, 2010)
Brunet v. State
442 So. 2d 638 (Louisiana Court of Appeal, 1983)
Dunaway v. Louisiana Wildlife & Fisheries Commission
903 So. 2d 467 (Supreme Court of Louisiana, 2005)

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