Ronnie Griffith v. CMR Construction & Maintenance Resources and LCTA Workers' Compensation

CourtLouisiana Court of Appeal
DecidedApril 13, 2022
Docket54,443-WCA
StatusPublished

This text of Ronnie Griffith v. CMR Construction & Maintenance Resources and LCTA Workers' Compensation (Ronnie Griffith v. CMR Construction & Maintenance Resources and LCTA Workers' Compensation) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ronnie Griffith v. CMR Construction & Maintenance Resources and LCTA Workers' Compensation, (La. Ct. App. 2022).

Opinion

Judgment rendered April 13, 2022. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,443-WCA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

RONNIE GRIFFITH Plaintiff-Appellant

versus

CMR CONSTRUCTION & Defendants-Appellees MAINTENANCE RESOURCES AND LCTA WORKERS’ COMPENSATION

Appealed from the Office of Workers’ Compensation, District 1-E Parish of Ouachita, Louisiana Trial Court No. 19-07501

Brenza I. Jones Workers’ Compensation Judge

HUDSON, POTTS & BERNSTEIN, L.L.P. Counsel for Appellant By: Brian P. Bowes

THE ANZELMO LAW FIRM Counsel for Appellees By: Donald J. Anzelmo Benjamin D. Jones

Before PITMAN, STEPHENS, and THOMPSON, JJ. STEPHENS, J.

On October 1, 2019, claimant, Ronnie Griffith, was seriously injured

when he fell through the roof of an airplane hangar at the Monroe Regional

Airport while employed as a construction foreman by defendant, CMR

Construction & Maintenance Resources, Inc. (“CMR”). As a result of his

30-foot fall to the concrete floor, Griffith sustained numerous broken bones

and internal injuries.

Griffith filed a disputed claim for compensation on November 8,

2019, against his employer and its insurer, LCTA Workers’ Compensation,

seeking the authorization of medical treatment and payment of disability

benefits, together with the imposition of penalties and an award of attorney

fees. Defendants filed an answer on December 16, 2019, denying that

Griffith was entitled to benefits because his accident was caused by his

intoxication at the time of the accident in accordance with La. R.S. 23:1081.

Defendants amended their answer to add the defense of fraud pursuant to La.

R.S. 23:1208 and seek forfeiture of all benefits as well as full restitution of

benefits previously paid, attorney fees, costs of litigation, and court costs.

That the accident occurred in the course and scope of claimant’s

employment and causation of Griffith’s injuries were not in dispute. The

issues to be decided by the workers’ compensation judge (“WCJ”) were

claimant’s entitlement to indemnity benefits; his entitlement to medical

benefits; the nature and extent of his injury; whether penalties and attorney

fees were appropriate; or, whether Griffith should be ordered to forfeit all

benefits and/or pay restitution, attorney fees, etc., pursuant to La. R.S.

23:1208. However, before addressing any of these issues, the WCJ was

tasked with determining whether the intoxication defense was applicable, and if so, whether claimant could overcome the presumption of causation

afforded the employer by La. R.S. 23:1081.

Most of the witness testimony was by deposition, stipulation, and/or

report. The only live testimony at the Zoom videoconference trial was that

of claimant Ronnie Griffith. Following presentation of the evidence and

after taking the matter under advisement, the WCJ found that defendants

proved that Griffith was intoxicated at the time of his accident, and that this

intoxication was causally linked to the accident. The WCJ further found

that claimant failed to prove that his intoxication was not a contributing

cause of the accident. Therefore, his claim for benefits was denied. The

WCJ also specifically found that “[a]ll other requests are denied, and this

matter is dismissed with prejudice.” It is from this judgment that claimant

has appealed, and defendants have filed an answer to the appeal.

DISCUSSION

Disqualification of Claimant for Workers’ Compensation Benefits

In his first three assignments of error, claimant asserts that the WCJ

erred in relying on the following evidence to disqualify him from benefits

pursuant to La. R.S. 23:1081: his employer’s drug testing policy; the drug

test requested by his employer, CMR, which failed to conform with

Louisiana’s Drug Testing Statutes, La. R.S. 49:1001, et seq., and the

Substance Abuse Mental Health Services Administration (SAMHSA)

Guidelines; and, the expert report prepared by toxicologist William George.

Griffith further urges that this evidence was insufficient to support the

WCJ’s conclusion that CMR was entitled to the La. R.S. 23:1081

presumption of intoxication, but if the presumption was established, then the

2 WCJ erred in failing to find that he introduced sufficient evidence to rebut

the presumption of intoxication.

Defendants contend that they established a prima facie case that

Griffith was intoxicated at the time of his accident—all they were required

to do under La. R.S. 23:1081(5) and (8) for CMR to be entitled to a

presumption that claimant was intoxicated and that this intoxication was a

cause of his accident was show that claimant was intoxicated due to drug use

by a preponderance of the evidence—and the record supports the trial

court’s finding that they did so. Furthermore, urge defendants, the record

supports the trial court’s determination that claimant failed to overcome this

presumption.

As noted above, that the accident occurred in the course and scope of

claimant’s employment and causation of Griffith’s injuries were not in

dispute. The first issues addressed by the WCJ in this case were whether the

intoxication defense was applicable and, if so, whether claimant could

overcome the presumption of causation provided the employer by this

defense.

Louisiana Revised Statute 23:1081 prohibits workers’ compensation

benefits for injuries caused by an injured employee’s intoxication at the time

of the injury. La. R.S. 23:1081(1)(b). The employer has the burden of

proving the intoxication. La. R.S. 23:1081(2). In order to support a finding

of intoxication to drug use, and a presumption of causation due to such

intoxication, the employer must prove the employee’s use of a controlled

dangerous substance, such as marijuana, by a preponderance of the evidence.

La. R.S. 23:1081(8); Nivens v. Fields, 46,524 (La. App. 2 Cir. 11/16/11), 79

So. 3d 1144. 3 In meeting this burden, the results of employer-administered tests

shall be considered admissible evidence when these tests are the result of the

testing for drug usage done by the employer pursuant to a written and

promulgated substance abuse rule or policy established by the employer. La.

R.S. 23:1081(8). An employer has the right to administer drug and alcohol

testing or demand that the employee submit himself to drug and alcohol

testing immediately following an alleged job accident. La. R.S.

23:1081(7)(a); Beck v. Newt Brown Contractors, LLC, 46,523 (La. App. 2

Cir. 9/21/11), 72 So. 3d 982, writ denied, 2011-2352 (La. 12/2/11), 76 So.

3d 1180. The collection, handling, and testing process must be trustworthy.

Nivens, supra. If there is, at the time of the accident, evidence of either on

or off the job use of marijuana, then it shall be presumed that the employee

was intoxicated at the time of the accident. La. R.S. 23:1081(5); Nivens,

supra; Deal v. Bancroft Bag, Inc., 28,188 (La. App. 2 Cir. 4/3/96), 671 So.

2d 1264, writ denied, 1996-1102 (La. 6/7/96), 674 So. 2d 977.

Once the employer has met the burden of proving that the employee

was intoxicated at the time of the accident, it is also presumed that the

employee’s injury was caused by his intoxication. La. R.S. 23:1081(12).

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Ronnie Griffith v. CMR Construction & Maintenance Resources and LCTA Workers' Compensation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronnie-griffith-v-cmr-construction-maintenance-resources-and-lcta-lactapp-2022.