Hoskins v. Amazon

CourtSuperior Court of Delaware
DecidedJuly 23, 2024
DocketN23A-06-004 CEB
StatusPublished

This text of Hoskins v. Amazon (Hoskins v. Amazon) 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
Hoskins v. Amazon, (Del. Ct. App. 2024).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

MATTHEW HOSKINS, ) ) Claimant Below- ) Appellant and Cross Appellee, ) ) v. ) C.A. No. N23A-06-004 CEB ) AMAZON.COM, ) ) Employer Below- ) Appellee and Cross Appellant. )

Submitted: May 14, 2024 Decided: July 23, 2024

MEMORANDUM OPINION

Upon Consideration of the Appeal from the Decision of the Industrial Accident Board, AFFIRMED.

Walter F. Schmittinger, Esquire, SCHMITTINGER & RODRIGUEZ, P.A., Dover, Delaware. Attorney for Claimant Below- Appellant and Cross Appellee.

John J. Ellis, Esquire, HECKLER & FRABIZZIO, P.A., Wilmington, Delaware. Attorney for Employer Below- Appellee and Cross-Appellant.

BUTLER, R.J. Background

This matter is an appeal and cross appeal from decisions of the Delaware

Industrial Accident Board (“IAB” or “Board”) concerning a claim made by

Claimant, Matthew Hoskins (“Claimant”) and his then employer, Appellee

Amazon.com (“Employer”).

Claimant was working as a “picker” at an Amazon fulfillment center in

Middletown, Delaware. In August, 2021, while so engaged, he was bending over a

bottom bin when a coworker reached up behind him to retrieve items from the top

of the bin, dislodging some merchandise boxes that then fell and hit Claimant on his

back. He reported the injury but continued to work for Amazon for another 5 months

or so, eventually quitting on account of his continuing complaints about his back

pain.

After the August injury, Claimant saw Doctor Balu for treatment of his back

pain. Dr. Balu took a medical history from Claimant and reviewed a recent MRI,

noting “lumbar lordosis and bulging discs at the L5-S1 level” as well as a herniated

disc at the L4-5 level. Claimant was treated with injections and put on work

restrictions.

In the face of continued complaints of pain, Dr. Balu gave Claimant anti-

inflammatory drugs, muscle relaxers and further injections.

1 Claimant also consulted a neurosurgeon, Dr. Pulak Ray, who proposed lumbar

surgery “due to severe degenerative disc disease at L4-5 causing foraminal stenosis.”

The cost of the surgery is what provoked Claimant to petition the IAB for

“Additional Compensation Due.” Claimant had already been receiving full

disability benefits since leaving Amazon. He now sought an Order from the IAB

that the Employer would be responsible for the surgery bills from Dr. Ray.

Thus, the critical issue, as discussed by the IAB in its Opinion denying

compensation, was whether the need for surgery was causally related to the incident

in August 2021, when the boxes fell on the Appellant.

Procedural History – Issues in Dispute

While the Court appreciates that the causal relationship between the

workplace incident and the need for surgery on Claimant’s spine is the central issue

on appeal, the pleadings have become further complicated by collateral issues that

are either waived or moot. The following is offered by way of explanation.

When Claimant filed his claim for Additional Compensation Due, the

Employer countered with a “Petition for Review,” a request to terminate Claimant’s

total disability benefits on the ground that he was physically able to return to work.

Employer had two witnesses to support this claim, a medical expert, Doctor Close,

2 and a vocational expert, Truman Perry, to present a “labor market survey” of jobs

available in the area.

For reasons not relevant to this appeal, the IAB barred Dr. Close’s testimony.

Despite the Employer’s motion to reargue and/or to continue the proceedings, the

Board’s ruling kept him out of the hearing. Without its medical expert, the Employer

presented the labor market expert anyway, apparently believing the testimony would

support its request to terminate Claimant’s total disability benefits.

Ultimately, the Board did not accept Employer’s argument that Claimant was

not totally disabled. This rendered the labor market survey of no value to the

Employer and a non-issue in this dispute.

The Employer filed a cross appeal on the denial of its Petition for Review. It

identified the Board’s refusal to allow the testimony of its medical expert Dr. Close

as its grounds for this appeal. The Employer did not, however, address this issue in

its Answering Brief or otherwise. That issue is therefore waived and will not be

considered further.

As to the vocational expert who did testify, the Claimant protested the

admissibility of this testimony in its Opening Brief, even though Claimant did not

identify that issue in its Notice of Appeal. 1 The Court has enough to do without

1 See Notice of Appeal, Trans. ID 70167531 (June 8, 2023). 3 rendering advisory opinions. The vocational expert was a non-factor in the Board’s

decision.

Moreover, Superior Court Rule 72 requires that “In all appeals from the

Industrial Accident Board, where the claimant accepts part of the award while

appealing the remainder of the award, the notice of appeal must specify that portion

of the award accepted.” 2 Claimant’s Notice of Appeal not only failed to identify the

admissibility of the vocational expert’s testimony, it affirmatively represented that

the appeal was “limited to the Board’s denial of Claimant’s petition for surgical

authorization” and it was “not appealing the denial of the Employer’s Petition for

Review.”3 Thus, the argument raised in Claimant’s Opening Brief concerning the

admissibility of the vocational expert is not preserved for review.

Finally, Claimant’s Reply Brief raises, for the first time, an argument seeking

affirmation of the Board’s refusal to permit the testimony of Employer’s expert, Dr.

Close. The problem here is that the Employer did not raise this issue in its briefing

at all, apparently choosing to abandon the question before briefing. The question is

not properly raised or preserved. The Court will not consider an issue raised for the

first time in a reply brief.4

2 Super. Ct. Civ. R. 72(c). 3 See Notice of Appeal. 4 See e.g., Paikin v. Vigilant Ins. Co., 2013 WL 5488454 at *3 n. 12 (relying on Mateson Chem. Corp. v. Barton, 2008 WL 142510, at *1 n.5 (Del. Super. Jan. 15, 2008)). 4 With all of that said, we will now move on to the single issue that is properly

preserved for review.

I. The Board’s Ruling Was Supported by Substantial Evidence

a. Causation is a question of fact.

Is the causal relationship between the Appellant’s need for back surgery and

his workplace incident a question of fact or a question of law? The case law and the

Restatement are virtually unanimous that causation is a question of fact.5 Thus, the

Board’s conclusion that Appellant’s need for surgery was not caused by his

workplace injury may not be second guessed by this Court.

Perhaps understanding that this is a problem for Claimant, he says instead that

“whether the Board committed legal error and the opinions of the Claimants treating

doctors should have been rejected is a question of law and is reviewed de novo” 6

citing Duvall v. Charles Connell Roofing. 7

But that is not what Duvall v. Charles Connell Roofing says. Rather, in

Duvall, the Supreme Court reversed precedent concerning the “unusual exertion”

rule to the availability of worker’s compensation when injuries occur on a worksite.8

5 See Restatement (Second) of Torts § 434(2); Duphily v. Delaware Elec.

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

Related

Duphily v. Delaware Electric Cooperative, Inc.
662 A.2d 821 (Supreme Court of Delaware, 1995)
Duvall v. Charles Connell Roofing
564 A.2d 1132 (Supreme Court of Delaware, 1989)
Lemmon v. Northwood Construction
690 A.2d 912 (Supreme Court of Delaware, 1996)

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