James Viars (Deceased) Estate v. Cumberland Mill Work & Supply,inc.

CourtCourt of Appeals of Kentucky
DecidedFebruary 2, 2022
Docket2021 CA 001178
StatusUnknown

This text of James Viars (Deceased) Estate v. Cumberland Mill Work & Supply,inc. (James Viars (Deceased) Estate v. Cumberland Mill Work & Supply,inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Viars (Deceased) Estate v. Cumberland Mill Work & Supply,inc., (Ky. Ct. App. 2022).

Opinion

RENDERED: FEBRUARY 4, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-1178-WC AND NO. 2021-CA-1276-WX

JAMES VIARS (DECEASED) ESTATE; BETTY STEWART, ADMINISTRATRIX; MANDI EMERSON AS NEXT FRIEND OF ALEXANDER VIARS, A MINOR; MANDI EMERSON AS NEXT FRIEND OF GIANNH VIARS, A MINOR; AND ANGELLA CAMPBELL AS NEXT FRIEND OF ELIAS HAWK YOUNG, A MINOR APPELLANTS/CROSS-APPELLEES

PETITION/CROSS-PETITION FOR REVIEW OF A DECISION v. OF THE WORKERS’ COMPENSATION BOARD ACTION NO. WC-18-50746

CUMBERLAND MILLWORK & SUPPLY, INC.; HONORABLE GRANT S. ROARK, ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD APPELLEES/CROSS-APPELLANTS OPINION AFFIRMING IN PART, REVERSING IN PART, AND REMANDING

** ** ** ** **

BEFORE: LAMBERT, MAZE, AND L. THOMPSON, JUDGES.

THOMPSON, L., JUDGE: The Estate of James Viars, et al., appeal from a

decision of the Workers’ Compensation Board (hereinafter “Board”) which

affirmed in part, reversed in part, and remanded a decision of an administrative law

judge (hereinafter “ALJ”). Appellants argue that a statute which, under certain

circumstances, denies workers’ compensation benefits to an employee who is

injured while intoxicated does not apply, contrary to the Board’s decision.

Cumberland Millwork & Supply, Inc. (hereinafter “Cumberland”) cross-appeals

and argues that a blood test is not required to prove a person’s intoxication and that

any workers’ compensation benefits awarded should be reduced due to James

Viars’ not utilizing safety equipment. We agree with Appellant that the statute at

issue does not apply here. We also agree with Cumberland that the testing of a

person’s blood is not required, but also conclude that there was insufficient

evidence presented that Mr. Viars was intoxicated. We affirm in part, reverse in

part, and remand.

-2- FACTS AND PROCEDURAL HISTORY

Mr. Viars was employed by Cumberland. On December 21, 2018,

Mr. Viars was making deliveries for Cumberland when he was involved in a motor

vehicle accident that resulted in his death. It is undisputed that his death occurred

during the course and scope of his employment. Mr. Viars did not die immediately

and was in the hospital for a number of days. During his hospitalization,

amphetamines, methamphetamines, and cannabinoids were found in his urine.

Mr. Viars’ estate and dependents sought workers’ compensation

benefits after his death. Cumberland indicated it would defend against the benefits

by alleging the accident was caused by Mr. Viars’ intoxication. Cumberland also

alleged that Mr. Viars was not utilizing the required safety equipment, a seatbelt,

when the accident occurred.

The primary issue in this appeal revolves around the interpretation of

Kentucky Revised Statutes (KRS) 342.610. The current version of this statute,

which was in effect at the time of Mr. Viars’ accident, states in relevant part:

(1) Every employer subject to this chapter shall be liable for compensation for injury, occupational disease, or death without regard to fault as a cause of the injury, occupational disease, or death.

...

(3) Liability for compensation shall not apply to injury, occupational disease, or death to the employee if the

-3- employee willfully intended to injure or kill himself, herself, or another.

(4) If an employee voluntarily introduced an illegal, nonprescribed substance or substances or a prescribed substance or substances in amounts in excess of prescribed amounts into his or her body detected in the blood, as measured by a scientifically reliable test, that could cause a disturbance of mental or physical capacities, it shall be presumed that the illegal, nonprescribed substance or substances or the prescribed substance or substances in amounts in excess of prescribed amounts caused the injury, occupational disease, or death of the employee and liability for compensation shall not apply to the injury, occupational disease, or death to the employee.

The previous version of this statute is also relevant for our purposes and stated in

relevant part: “(3) Liability for compensation shall not apply where injury,

occupational disease, or death to the employee was proximately caused primarily

by voluntary intoxication as defined in KRS 501.010, or by his or her willful

intention to injure or kill himself, herself, or another.” KRS 342.610(3) (amended

2018). Voluntary intoxication is defined as “intoxication caused by substances

which the defendant knowingly introduces into his body, the tendency of which to

cause intoxication he knows or ought to know, unless he introduces them pursuant

to medical advice or under such duress as would afford a defense to a charge of

crime.” KRS 501.010(4).

-4- With these statutes in mind, we now turn to the evidence presented to

the ALJ. It is undisputed that there was no test on Mr. Viars’ blood during his

hospitalization. Appellants’ expert, Michael Ward,1 testified that the detection of

drugs in Mr. Viars’ urine did not indicate that the drugs were in Mr. Viars’ blood at

the time of the accident. He testified that the only way to detect whether drugs

were in Mr. Viars’ blood at the time of the accident, and in what amounts, would

have been to test his blood. He testified that urine tests are not good for

determining a person’s impairment from drugs. Mr. Ward’s opinion was that a

person’s urine could test positive for drugs, but that the drugs may have already

been cleared from the blood.

Cumberland presented the testimony of its expert, Dr. Daniel

Wolens.2 He testified that Mr. Viars’ urine was tested three times over a forty-

eight-hour period. It was his opinion that since the drugs were present in the urine

over this period of time, Mr. Viars had to ingest the drugs close to the time of the

accident.

1 Mr. Ward is a forensic toxicologist who is an adjunct professor at Eastern Kentucky University, an assistant professor at the University of Kentucky, and owns a consulting firm, Toxchem, Inc. 2 Dr. Wolens is a doctor with Kentuckiana Occupational Health Associates, Ltd. He is board certified in preventative medicine, a member of the American Board of Quality Assurance and Utilization Review Physicians, and a member of the American Board of Independent Medical Examiners.

-5- The primary contested issue in this case was the application of KRS

342.610(4). Cumberland maintained Mr. Viars was intoxicated at the time of the

accident; therefore, he was not entitled to benefits. Appellants argued that since

Mr. Viars’ blood was not tested, KRS 342.610(4) does not apply. The ALJ found

that Mr. Ward’s testimony was more persuasive and held that Mr. Viars’ blood was

not “scientifically, reliably tested to determine the presence of illegal substances at

levels which would cause a disturbance of mental or physical capacities.” The

ALJ held Cumberland did not carry its burden of establishing the intoxication

affirmative defense; therefore, the benefits claim was not barred by KRS

342.610(4).

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