Corey Ferrell v. City of Wilmington IAB

CourtSupreme Court of Delaware
DecidedDecember 4, 2025
Docket152, 2025
StatusPublished

This text of Corey Ferrell v. City of Wilmington IAB (Corey Ferrell v. City of Wilmington IAB) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Corey Ferrell v. City of Wilmington IAB, (Del. 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

COREY FERRELL, § § No. 152, 2025 Claimant Below, § Appellant, § § Court Below: Superior Court v. § of the State of Delaware § CITY OF WILMINGTON § C. A. No. N24A-08-004 § Employer Below, § Appellee. §

Submitted: October 8, 2025 Decided: December 4, 2025

Before SEITZ, Chief Justice; VALIHURA and LEGROW, Justices.

Upon appeal from the Superior Court of the State of Delaware. AFFIRMED.

Gary S. Nitsche, Esquire, James Gaspero Jr., Esquire, NITSCHE & FREDRICKS, LLC, Wilmington, Delaware, for Appellant Corey Ferrell.

Gregory P. Skolnik, Esquire, HECKLER & FRABIZZIO, PA, Wilmington, Delaware, for Appellee City of Wilmington.

LEGROW, Justice: In 2015, Corey Ferrell sustained a compensable work injury to his back while

working in a part-time capacity for the Belvedere Fire Company (“Belvedere”). In

2018, Ferrell accepted a commutation of the 2015 claim with Belvedere’s workers’

compensation insurance carrier. The commutation globally resolved the claim and

released the insurer from further liability with respect to the injury.

In 2023, Ferrell injured his back while working for the Wilmington Fire

Department (“Wilmington FD”). Wilmington FD denied Ferrell’s claim for

workers’ compensation, and the parties submitted the disputed claim to the Industrial

Accident Board (“IAB” or the “Board”).

After receiving evidence, the Board held that the 2023 incident was a

recurrence of Ferrell’s 2015 injury rather than an aggravation of that injury. Under

settled law, a recurrence of a work injury is compensable by the original carrier that

covered that injury, while an aggravation of an injury caused by a second accident

or event is compensable by the carrier that insured the employer at the time of the

aggravation. In most instances, the distinction between a recurrence and an

aggravation simply apportions liability between carriers and does not result in a lapse

of coverage for a worker. But because Ferrell commuted his first claim and released

Belvedere from further liability, he could not recover unless the 2023 injury was an

1 aggravation caused by a second event. Accordingly, the Board’s holding left Ferrell

without a compensable claim. The Superior Court affirmed the Board’s decision.1

On appeal, Ferrell urges us to reverse on two independent grounds. First, he

contends that the Board used the wrong standard when it applied the “aggravation”

versus “recurrence” analysis announced in Standard Distributing Co. v. Nally.2

Ferrell further contends that the 2023 incident was an untoward and intervening

event that created a separate compensable injury. Second, Ferrell argues that the

Board’s decision is not supported by substantial evidence. We find that the Superior

Court and the Board applied the correct standard, and the Board’s decision was

supported by substantial evidence. We therefore affirm the Board’s judgment.

I. RELEVANT FACTUAL AND PROCEDURAL BACKGROUND3

A. Ferrell’s 2015 injury, treatment, and commutation

In 2015, Ferrell was employed by Belvedere on a part-time basis and

employed full time with Appellee Wilmington FD.4 While working for Belvedere,

Ferrell was involved in a motor vehicle crash that caused an injury to his back. An

1 Ferrell v. City of Wilmington, 2025 WL 753378 (Del. Super. Mar. 10, 2025). 2 630 A.2d 640, 644–46 (Del. 1993) (“The rule we endorse for determining successive carrier responsibility in recurrence/aggravation disputes places responsibility on the carrier on the risk at the time of the initial injury when the claimant, with continuing symptoms and disability, sustains a further injury unaccompanied by any intervening or untoward event which could be deemed the proximate cause of the new condition.”). 3 The facts, unless otherwise noted, are drawn from the Superior Court’s Memorandum Opinion affirming the Board’s decision. Ferrell, 2025 WL 753378. 4 App. to Appellant’s Opening Br. [hereinafter “A__”] at A39-40 (IAB Hr’g Tr.).

2 MRI performed after the accident identified bulges and herniations in Ferrell’s spine.

Ferrell filed a workers’ compensation claim and underwent various treatments. In

2017, Ferrell “received a settlement for 6% permanency to [his] cervical spine and

5% permanency to [his] thoracic spine.”5

In 2018, Ferrell accepted a global commutation of his 2015 claim against

Belvedere’s workers’ compensation carrier. In the commutation Ferrell agreed:

“[i]n exchange for releasing the workers’ compensation carrier from future benefit

liability described above, I’m accepting a lump sum benefit in the form of waiver of

the workers’ compensation carrier’s lien credit, which I would otherwise be

obligated to repay from the proceeds of a third party settlement.”6 Under this

agreement, Ferrell settled the 2015 claim outright and released Belvedere’s carrier

from “future benefit liability.”7 Ferrell later returned to work and continued his

duties as a firefighter.

After Ferrell returned to firefighting, there is no record that he was unable to

work due to his 2015 spinal injury. In 2021, however, he was rear-ended in a non-

work-related motor vehicle crash. Several weeks after the 2021 crash, Ferrell

experienced back spasms and eventually sought care from his family physician, Dr.

5 A62 at 34:19–21 (IAB Hr’g Tr.). 6 A61 at 33:10–15 (IAB Hr’g Tr.). 7 Id. at 33:11–12 (IAB Hr’g Tr.) (emphasis added).

3 Tucker.8 The pain from this 2021 crash was reportedly significant. Dr. Tucker

ordered an x-ray and treatment in 2021, but Ferrell could not recall whether he

completed any of the recommended follow-up treatment.

B. The October 6, 2023 incident

On October 6, 2023, while working for Wilmington FD, Ferrell responded to

a call at a high-rise apartment building. High-rise buildings may require firefighters

to carry special equipment in a “high-rise pack” that can weigh 30–40 pounds. When

Ferrell’s unit arrived at the high-rise building, one of his supervising officers did not

pick up his designated high-rise pack. Ferrell felt that the pack was essential

equipment and decided to carry both the officer’s pack and his own.

After ascending approximately three flights of stairs with the two packs,

Ferrell began to experience a sudden shortness of breath accompanied by chest pain.

He was able to get himself “back together” and returned to the fire station with the

other firefighters.9 At the station, Ferrell reported experiencing back spasms and

shortness of breath. He also testified that he felt a “pop” in his back when he was

ascending the stairs, but the timeline of when Ferrell reported the “pop” is not clear.10

8 This period was during the COVID-19 pandemic and Ferrell reportedly delayed seeing Dr. Tucker for treatment. A64 at 36:4–16 (IAB Hr’g Tr.). 9 A42 at 14:20 (IAB Hr’g Tr.). 10 Appellee’s Answering Br. at 17 (“Although there was one note late in the game that recorded a history of [Ferrell] feeling a pop, that history was inconsistent with records from many other providers more contemporaneous to the alleged event.”).

4 Ferrell was transported to the hospital to evaluate his chest pain and shortness of

breath. Ultimately, doctors concluded that Ferrell’s cardiac health was not impaired.

Ferrell was advised to follow-up with his physician regarding the reported

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

Related

Duvall v. Charles Connell Roofing
564 A.2d 1132 (Supreme Court of Delaware, 1989)
Person-Gaines v. Pepco Holdings, Inc.
981 A.2d 1159 (Supreme Court of Delaware, 2009)
Betts v. Townsends, Inc.
765 A.2d 531 (Supreme Court of Delaware, 2000)
Oceanport Industries, Inc. v. Wilmington Stevedores, Inc.
636 A.2d 892 (Supreme Court of Delaware, 1994)
Breeding v. Contractors-One-Inc.
549 A.2d 1102 (Supreme Court of Delaware, 1988)
DiSabatino & Sons, Inc. v. Facciolo
306 A.2d 716 (Supreme Court of Delaware, 1973)
Pennsylvania Manufacturer's Ass'n Insurance v. Home Insurance Co.
584 A.2d 1209 (Supreme Court of Delaware, 1990)
Noel-Liszkiewicz v. La-Z-Boy
68 A.3d 188 (Supreme Court of Delaware, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Corey Ferrell v. City of Wilmington IAB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/corey-ferrell-v-city-of-wilmington-iab-del-2025.