Christiana Care Health Services v. DavisAnnotate this Case
Kenneth Davis was employed by Christiana Care Health Services as a dishwasher in its Nutrition Services department. In 2012, Davis was working when he slipped and fell backwards, landing on his back. A doctor saw Davis for a defense medical examination on in early 2013. The doctor wrote a report indicating “that any low back injury causally related to the work accident was “resolved” and any ongoing symptoms were non-work related.” Approximately one month later, Christiana Care’s counsel sent an “extremely modest” settlement offer to Davis’s attorney. Although it extended this settlement offer, Christiana Care’s position was that Davis’s back injury was due to a pre-existing gunshot injury that was unrelated to Davis’s employment. To the extent that any injury during his work contributed to Davis’s back troubles, Christiana Care maintained that this was resolved as of February 27, 2013 when Dr. Crain examined him. This appeal addressed the Superior Court’s decision to overrule a determination by the Industrial Accident Board (the “IAB”) that the parties had reached a settlement agreement, which barred a later claim for benefits due to permanent impairment. Because it lacked a complete release that would have avoided any question about its effect, the settlement agreement was “less than ideally clear.” But the IAB’s factual determination that the parties’ settlement, which involved an express agreement that the injury in question was resolved as an ongoing medical matter, precluded a future claim for permanent impairment based on the same “resolved” injury was supported by substantial evidence. The Superior Court was required to defer to the IAB’s factual determinations to the extent they were supported by substantial evidence, and in this case, the Superior Court erred by substituting its own factual findings for that of the IAB. Moreover, there was no question that the settlement agreement was, as a legal matter, a binding contract supported by adequate consideration. Therefore, the Supreme Court reversed the Superior Court’s decision and reinstated the IAB’s determination.