Russellville Electric Plant Board v. Christopher Thomas

Kentucky Supreme Court·Decided August 20, 2026·No. 2025-SC-0422·Unpublished

Opinion

IMPORTANT NOTICE

“NOT TO BE PUBLISHED OPINION”

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED” PURSUANT TO RULE OF APPELLATE PROCEDURE (RAP) 40(D). THIS OPINION SHALL NOT BE CITED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE. UNDER RAP 41, UNPUBLISHED OPINIONS OF KENTUCKY APPELLATE COURTS RENDERED AFTER JANUARY 1, 2003, THAT ARE FINAL UNDER RAP 40(G), MAY BE CITED BY A PARTY FOR CONSIDERATION BY A COURT IF THERE IS NO PUBLISHED OPINION THAT ADEQUATELY ADDRESSES THE POINT OF LAW BEING ARGUED BY A PARTY. IF AN UNPUBLISHED OPINION IS CITED FOR CONSIDERATION BY A COURT THE OPINION SHALL BE SET OUT AS AN UNPUBLISHED OPINION IN THE DOCUMENT IN WHICH THE UNPUBLISHED OPINION IS CITED.

RENDERED: AUGUST 20, 2026 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2025-SC-0422-WC

RUSSELLVILLE ELECTRIC PLANT APPELLANT/CROSS-APPELLEE BOARD

ON APPEAL FROM COURT OF APPEALS V. NO. 2025-CA-0540 WORKERS' COMPENSATION NO. WC-23-00706

CHRISTOPHER THOMAS APPELLEE/CROSS-APPELLANT AND

HONORABLE CHRIS DAVIS, APPELLEES ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD OF KENTUCKY

AND 2025-SC-0433-WC

CHRISTOPHER THOMAS CROSS-APPELLANT

ON APPEAL FROM COURT OF APPEALS V. NO. 2025-CA-0540 WORKERS' COMPENSATION NO. WC-23-00706

RUSSELLVILLE ELECTRIC PLANT CROSS-APPELLEES BOARD; HONORABLE CHRIS DAVIS, ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD OF KENTUCKY

MEMORANDUM OPINION OF THE COURT AFFIRMING

This appeal concerns the compensability of an injury arising from COVID-19. Russellville Electric Plant Board (“REPB”) appeals the Court of Appeals’ opinion reversing, in part, the Workers’ Compensation Board’s (“Board”) opinion vacating and remanding the Administrative Law Judge’s (“ALJ”) award, opinion, and order (“award”). REPB argues that the Board correctly vacated the award due to the ALJ’s failure to apply the proper legal standard when assessing the compensability of a work-related communicable disease. REPB further contends that the Board properly concluded that the ALJ misinterpreted the University Evaluator’s report on causation. Christopher H. Thomas (“Thomas”) cross-appeals from the Court of Appeals’ opinion affirming, in part, the Board’s opinion vacating and remanding the ALJ’s award with instructions that the ALJ reexamine whether Thomas’ injury is work- related. Thomas argues that the ALJ applied the appropriate legal standard and based the award on findings of fact supported by substantial evidence of record, including the University Evaluator’s report. For the reasons set forth below, we affirm the Court of Appeals' opinion.

BACKGROUND

In 2006, REPB employed Thomas as a lineman. In 2008, Thomas became line foreman. As line foreman, Thomas supervised a crew of four linemen and assigned individual jobs to each crew member. Thomas’ crew shared an office and frequently ate meals together. The crew also shared

transportation to various worksites via REPB-owned trucks, including four bucket trucks and one pickup truck. Notably, REPB provided Thomas with his own pickup truck. Thomas had the discretion to allow members of his crew to ride with him to worksites.

On July 24, 2021, Thomas began experiencing symptoms consistent with COVID-19. On July 26, 2021, Thomas received a positive COVID-19 test result. Thomas alleges that he contracted COVID-19 at work due to close, sustained contact with other REPB employees who were “shedding” the virus. Thomas’ crew members included Mark Venable (“Venable”), John Byrns, Jesse Steenbergen, and Alan Jones (“Jones”). Thomas claims that, at a minimum, he was exposed to COVID-19 through contact with Venable and Jones during the week of July 19, 2021. Thomas believes he contracted COVID-19 when he drove Venable or Jones to worksites and worked alongside both linemen.

Thomas’ allegations focus on his exposure related to Venable, who commuted with him to jobsites from July 19, 2021, through July 22, 2021. In particular, Thomas asserts that on July 20, 2021, Venable disclosed to Dale Vowell (“Vowell”), the REPB general manager, that he had been exposed to COVID-19. Vowell advised Venable to continue working unless he tested positive for COVID-19 or showed signs of illness. Venable worked on July 21, 2021, and July 22, 2021. While REPB either encouraged or required masks when workers commuted together, neither Venable nor Thomas wore a mask during the relevant time. On the morning of July 23, 2021, Venable informed

Vowell that he was experiencing symptoms. Vowell instructed Venable to remain at home.

The following day, on July 24, 2021, Thomas became ill and submitted to a COVID-19 test. On July 26, 2021, Thomas’ COVID-19 test returned positive. Within one week, Thomas’ infection became severe enough to develop COVID- 19-related pneumonia. As a result, Thomas was admitted to the Bowling Green Medical Center Intensive Care Unit and placed on a ventilator for approximately 78 days. On November 21, 2021, doctors transferred Thomas to a rehabilitation center. Finally, on December 1, 2021, Thomas returned to his residence. Thomas has since suffered both respiratory and neurocognitive impairment.

Thomas did not return to work after his hospitalization. He used accrued and donated sick time, followed by long-term disability benefits, until mid- 2023. Thereafter, on July 17, 2023, Thomas filed a claim for workers’ compensation benefits via Form 101 and Form 102, the former an application for benefits for a work-related communicable disease injury and the latter alleging a work-related occupational disease injury. Thomas also alleged that REPB committed a safety violation pursuant to Kentucky Revised Statute (“KRS”) 342.165. At his administrative hearing, Thomas introduced several medical expert opinions supporting his claim. For example, he introduced an Independent Medical Examination report by Dr. Jules Barefoot stating that Thomas was exposed to COVID-19 at work on July 21, 2021, resulting in a COVID-19 infection. Dr. Barefoot assessed a 58% whole-person impairment

rating, attributing 100% of the impairment to workplace exposure to COVID- 19.

At issue before this Court is the Form 108 report completed by the appointed University Evaluator, Dr. Bob Moldoveanu (“Dr. Moldoveanu”). In his report, Dr. Moldoveanu diagnosed Thomas with chronic respiratory failure and post-COVID-19 syndrome due to work-related exposure. Dr. Moldoveanu assessed a 50% whole-person impairment rating and opined that Thomas lacked the capacity to return to the type of work he performed prior to his work-related injury.

On September 10, 2024, the ALJ issued the underlying award, which is the subject of this appeal. The ALJ rejected Thomas’ occupational disease claim and instead focused on whether COVID-19 qualifies as a compensable work- related injury under Kentucky Revised Statute (“KRS”) 342.0011(1). In analyzing Thomas’ claim, the ALJ found that (1) Thomas was required to frequently “ride in trucks” with other co-workers; (2) REPB neither required nor enforced a mask mandate; (3) Venable had reported exposure to COVID-19 and was instructed by Vowell to continue working alongside Thomas; and (4) prior to Thomas becoming symptomatic, his familial and personal contacts did not become symptomatic or test positive for COVID-19. The ALJ also gave presumptive weight to Dr. Moldoveanu’s opinion. Based on these findings, the ALJ concluded that Thomas contracted COVID-19 through work-related exposure.

The ALJ further found that Thomas’ working conditions increased the likelihood of contracting COVID-19. The ALJ concluded that “Thomas was an essential worker required to ride in a truck with a co-worker who had been exposed to the virus and was symptomatic and mask mandates were not enforced.” The ALJ reasoned that Thomas’ situation “is different, entirely, from a person who was allowed, or required, to stay home during the time period of March 2020, through end of the lockdown period” because he was considered an essential worker.

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Russellville Electric Plant Board v. Christopher Thomas, (Ky. 2026).

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