Nathaniel Edward Maysey v. Express Services, Inc.

CourtKentucky Supreme Court
DecidedMarch 22, 2021
Docket2020 SC 0132
StatusUnknown

This text of Nathaniel Edward Maysey v. Express Services, Inc. (Nathaniel Edward Maysey v. Express Services, Inc.) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nathaniel Edward Maysey v. Express Services, Inc., (Ky. 2021).

Opinion

RENDERED: MARCH 25, 2021 TO BE PUBLISHED

Supreme Court of Kentucky 2020-SC-0132-WC

NATHANIEL EDWARD MAYSEY APPELLANT

ON APPEAL FROM COURT OF APPEALS V. NO. 2018-CA-1121 WORKERS’ COMPENSATION BOARD NO. WC-16-81368

EXPRESS SERVICES, INC; APPELLEES HONORABLE W. GREG HARVEY, ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD

OPINION OF THE COURT BY JUSTICE HUGHES

AFFIRMING

Kentucky Revised Statute (KRS) 342.165(1) provides for a 30%

enhancement of workers’ compensation benefits if an accident is caused in any

degree by workplace safety violations committed by the employer. Appellant

Nathaniel Edward Maysey sustained a serious work-related injury on June 6,

2016 while employed by Express Services, Inc., a temporary staffing company.

Express Services placed Maysey at Magna-Tech Manufacturing, LLC where he

worked for five days operating machinery before being involved in an accident

that resulted in the amputation of his left arm above the elbow. Maysey settled

with Express Services prior to the final adjudication of his workers’

compensation claim. The sole remaining issue before the Administrative Law

Judge (ALJ) and now before this Court is whether Maysey is entitled to a 30% enhancement of benefits from his employer, Express Services, as a result of

workplace safety violations. The ALJ denied the enhancement and the Board

and the Court of Appeals affirmed. For the reasons discussed below, we affirm

the Court of Appeals, albeit with the reluctance expressed by the ALJ and

echoed by the Board and appellate court. As currently written, the safety-

violation benefit enhancement in Kentucky’s workers’ compensation statute

does not apply to a temporary staffing company employee except in extremely

limited circumstances, leaving a temporary employee without the same

entitlement to enhanced benefits as an injured employee of the host company.

FACTS AND PROCEDURAL HISTORY

Shortly after graduating from high school, Nathaniel Maysey obtained

employment with Express Services and was placed at Magna-Tech, a

manufacturing facility in Glasgow, Kentucky that performs impregnation of

casted automobile parts. His first day of work at Magna-Tech was June 1,

2016. On his sixth day at the facility, Maysey was assigned to Line 46. This

assignment involved operating multiple machines simultaneously from a

catwalk. Upon completion of the process using one machine, the employee

moved a basket of parts with a hoist to the next machine. Maysey was injured

on June 6, 2016, his first day working on Line 46.

The first machine on Line 46 was a dip tank. A bucket of parts was

lowered into the dip tank and then lifted out with a hook and placed in the next

machine, the centrifuge. Once in the centrifuge, the bucket rotated clockwise

then counter clockwise before completing the cycle. The employee was then

2 required to reach his hand into the machine and attach a hoist hook to the

bucket, then use the hoist hook and chain to lift the basket of parts and move

it to the next machine.

Maysey received minimal training (approximately one hour) and was left

on his own to feed buckets of parts through the six machines from his location

on the catwalk. He was performing this function and believed the centrifuge

had completed both cycles, so he reached in to connect the hoist hook to the

basket when the machine started up again. Both the chain and the cable

connected to the hook wrapped around his left arm and began to twist.

Maysey was concerned that the machine was going to pull him in, so he leaned

back. When he pulled away from the machine, his arm tore from his body just

above the left elbow. According to Maysey, the centrifuge did not have a light

that came on to indicate when the machine had completed both cycles. It also

did not have an emergency stop that was accessible.

After the accident, Maysey was flown to the University of Louisville

Hospital where he spent more than a month and underwent nine surgeries to

re-attach his left arm. Maysey currently has limited use of his left arm and, as

he demonstrated to the ALJ, is unable to grip or pick up objects with his

fingers. He also has a tingling sensation from his fingertips up to where his

arm was detached.

Maysey filed a claim for benefits and a safety violation complaint on May

19, 2017. The ALJ conducted a final hearing on November 21, 2017 and on

January 12, 2018 the parties informed the ALJ that they had settled all issues

3 except the alleged safety-violation enhancement. The sole issue before the ALJ

was whether Maysey’s benefits should be enhanced pursuant to KRS

342.165(1), the safety penalty statute which imposes a 30% enhancement of

benefits for accidents caused by the intentional failure of an employer to

comply with a statute or regulation relative to installation or maintenance of

safety appliances.

Several witnesses provided deposition testimony, including Maysey;

Kentucky Occupational Safety and Health Administration (OSHA) inspectors;

Magna-Tech’s Operations Manager; and Express Services’ Safety and

Operations Manager. One witness, Charles Morley, is an OSHA safety

compliance officer who routinely performs safety inspections throughout the

Commonwealth. After the accident Morley conducted a walk-through of the

area, interviewed employees, and took photographs. Morley learned that the

top that covers the centrifuge was always open during operation, thereby

allowing employees, including Maysey, to reach into the centrifuge’s point of

operation while the machine was still operating. He also learned that the

emergency stop on the railing in front of the centrifuge was inoperable.

Employees informed Morley that the centrifuge top was left open because

the indicator lights, which notified employees that the centrifuge had

completed its cycle, did not always function properly. By leaving the top open

employees could visually determine if the centrifuge had stopped spinning.

Morley asked that the machine be operated for him and Magna-Tech refused

the request.

4 Morley’s investigation included contacting Godfrey and Wing, the

manufacturer of the centrifuge. The manufacturer informed him that the

centrifuge was not designed to operate unless the top was closed. Additionally,

the centrifuge was designed and manufactured such that the top could not be

opened unless the centrifuge’s two cycles had come to a complete stop. This

was specifically done to prevent injury and effectuated by computer software

called logic control, which tells the machine when to move and when to stop.

Morley was informed by the manufacturer that for the machine to operate with

the top open, the computer program would have to be intentionally bypassed.

In the course of his investigation, Morley discovered that Maysey received

minimal training with another employee who had only been on the job three

months. When he was injured it was his first time operating the hoist on his

own and his trainer had to leave him to attend another machine, resulting in

Maysey being alone on the catwalk when the accident occurred. Morley

learned that other Magna-Tech employees were aware of the centrifuge’s

malfunctioning and concerned about its safety prior to Maysey’s injury, but

none of these concerns were reported to Magna-Tech or Express Services.

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

Related

Gray v. Trimmaster
173 S.W.3d 236 (Kentucky Supreme Court, 2005)
Jones v. AEROTEK STAFFING
303 S.W.3d 488 (Court of Appeals of Kentucky, 2010)
St. Clair v. Commonwealth
140 S.W.3d 510 (Kentucky Supreme Court, 2004)
Williams v. Eastern Coal Corp.
952 S.W.2d 696 (Kentucky Supreme Court, 1997)
Apex Mining v. Blankenship
918 S.W.2d 225 (Kentucky Supreme Court, 1996)
Button v. Hikes
176 S.W.2d 112 (Court of Appeals of Kentucky (pre-1976), 1943)
University of Louisville v. Rothstein, Mark
532 S.W.3d 644 (Kentucky Supreme Court, 2017)
Ernest Simpson Construction Co. v. Conn
625 S.W.2d 850 (Kentucky Supreme Court, 1981)
Parker v. Webster County Coal, LLC
529 S.W.3d 759 (Kentucky Supreme Court, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Nathaniel Edward Maysey v. Express Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/nathaniel-edward-maysey-v-express-services-inc-ky-2021.