Garrett v. Amazon.com, Inc.

CourtSuperior Court of Delaware
DecidedJune 1, 2018
DocketN17A-06-007 JAP
StatusPublished

This text of Garrett v. Amazon.com, Inc. (Garrett v. Amazon.com, Inc.) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garrett v. Amazon.com, Inc., (Del. Ct. App. 2018).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

PORTIA GARRETT, ) ) Claimant-Below Appellant, ) ) v. ) C.A. No. N17A-06-007 JAP ) AMAZON.COM, INC., ) ) Employer-Below Appellee. ) )

MEMORANDUM OPINION

Portia Garrett appeals from the decision of the Industrial

Accident Board, which denied her petition for worker’s

compensation. Garrett’s only contention on appeal is that the Board

erred when it refused to strike the testimony of her employer’s Site

Safety Specialist, Brian Martin. According to Garrett, Martin’s

testimony was “pure hearsay” since he was not present for an

“accident re-creation” investigation conducted by Amazon. The

judgment of the Board is affirmed for the reasons stated below.

BACKGROUND

Portia Garrett alleges that on October 14, 2015, she was injured

at work while employed by Amazon.com, Inc. as a quality control associate. Garrett filed a claim for worker’s compensation benefits

with the Department of Labor’s Industrial Accident Board in August

of 2016. The Board held its hearing on January 27, 2017, during

which Garrett presented deposition testimony from physician, Dr.

Mark Eskander, and her own testimony.

According to Garrett, she was sitting on a stool counting

product, when a fellow employee operating a device known as a pick

cart repeatedly pushed the cart into her left shoulder, jerking her

neck and shoulder and causing pain in those areas. Garrett did not

know the name of the employee that struck her, but described the

employee as a “foreign woman.” Garrett also testified that the

employee stopped and apologized when she struck her.

Contemporaneous evidence raises serious questions about the

credibility of this testimony. Testimony at the hearing revealed that

at the time of the accident, when Garrett reported it to her manager,

Garrett: (1) could not describe the employee that struck her; (2) did

not even know the employee’s gender; and (3) stated that the

employee never stopped after striking her. Because of the absence of

any meaningful description, Amazon was unable to identify the

employee that supposedly hit her. Garrett sought treatment at 2 Amazon’s in-house medical clinic and was later referred for outside

treatment. She said that about two weeks after the accident,

someone named “Ms. V” from Amazon’s Safety Department

conducted an “accident re-creation” investigation, during which

Garrett was present and participated.

Testimony also revealed that Garrett had injured her neck and

shoulder in car accidents in 2002, 2004, 2005, and 2008. And in

December 2014, while employed by Integrity Staffing Solutions, she

made a claim for a worker’s compensation based on an injury to her

left shoulder, which was denied. Notably, on her Amazon injury

report, Garrett denied any prior injuries to her left shoulder.

Amazon presented deposition testimony from Dr. Samuel Matz,

and also called its Site Safety Specialist, Brian Martin. Martin

testified from his personal knowledge that the pick cart and stool

were standard equipment with particular height, length, and width

specifications, and that the pick cart does not obstruct the operator’s

vision and can easily be maneuvered. Martin said that he could not

think of anyone with the name “Ms. V,” but rather, the re-creation

was done shortly after the accident by an employee named Jaime

Hall. Hall reported to Martin that the re-creation exercise was 3 “unsuccessful” in that they could not recreate the incident in the way

that Garrett described it because the push cart would have hit the

stool, and if it did hit Garrett at all, the highest shelf on the cart

would only reach as high as her mid-back, not her shoulder.

Martin was not personally present during the re-creation, but

he reviews all investigations and the notes and findings therefrom.1

He confirmed that any notes that he read and processed during

Amazon’s investigation were incorporated into a safety report, which

was produced to Garrett’s counsel.2 Garrett’s counsel did not

immediately object to Martin’s testimony after determining that he

was not present at the re-creation, choosing instead to continue

questioning Martin on forms Garrett completed after her December

2014 Integrity Staffing injury, her October 2015 Amazon injury, and

the treatment Garrett sought for those injuries.3

Only after Martin was excused from the witness stand, did

Garrett’s counsel object to Martin’s “entire testimony since we were

never given any of the written materials about the investigation and

the witness himself was not physically present at the reenactment

1 See App. to Opening Br., Ex. A (Hearing Tr., at 94:2-22). 2 Id. at 97:14-17. 3 Id. at 94:23—97:9. 4 that he described.”4 Amazon responded that everything from the

investigation and reenactment was contained in the report provided

to Garrett’s counsel before the hearing. The Board denied the motion

to strike, holding that the request to strike all of the witness’s

testimony was overbroad, but as to the “re-creation” testimony

specifically, the Board took note of the objection and stated it would

give the testimony the weight that it deserved considering that Martin

was not present for the re-creation.5

On May 30, 2017, the Board issued a written decision denying

Garrett’s petition for worker’s compensation benefits. Garrett filed

an appeal in the Superior Court on June 16, 2017. The court initially

scheduled oral argument, but before oral argument was held, Garrett

terminated her counsel. By Order dated February 27, 2018, Garrett

was given 90 days to obtain new counsel and notify the court. Garrett

has not retained new counsel and the court therefore feels that oral

argument would not be useful. Thus, upon consideration of the

briefs filed by the parties and the entire record below, this is the

court’s ruling.

4 Id. at 101:15-19. 5 Id. at 103:19-24. 5 ANALYSIS

On appeal, this court reviews a decision of the Industrial

Accident Board for errors of law to “determine whether substantial

evidence exists to support the Board’s finding of fact and conclusions

of law.”6 Substantial evidence is “such relevant evidence as a

reasonable mind might accept as adequate to support a conclusion.”7

This court reviews errors of law de novo, but absent an error of law,

the standard of review for the Board’s decision is abuse of discretion.8

“[T]he Rules of Evidence do not strictly apply to administrative

hearings. Rather, the agency may hear ‘all evidence which could

conceivably throw light on the controversy.’”9 Industrial Accident

Board Rule No. 14(b) states:

The rules of evidence applicable to the Superior Court of Delaware shall be followed insofar as practical, however, that evidence will be considered by the Board which, in its opinion, possesses any probative value commonly accepted by reasonably prudent men in the conduct of their affairs. The Board may, in its discretion, disregard any customary rules of evidence and legal procedures so long as such a disregard does not amount to an abuse of discretion.

6 Person-Gaines v. Pepco Holdings, Inc., 981 A.2d 1159, 1161 (Del. 2009). 7 Histed v. E.I. Du Pont de Nemours & Co., 621 A.2d 340

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Related

Histed v. E.I. Du Pont De Nemours & Co.
621 A.2d 340 (Supreme Court of Delaware, 1993)
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Person-Gaines v. Pepco Holdings, Inc.
981 A.2d 1159 (Supreme Court of Delaware, 2009)

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