Workagegnehu v. Washington Metropolitan Area Transit Authority, No. 19-7029 (D.C. Cir. 2020)
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Appellant seeks damages from WMATA for an assault he suffered while working, unsatisfied with a workers' compensation order to which he previously stipulated. Another employee at WMATA pinned appellant to the ground and punched him until he was unconscious. After appellant gained consciousness, the employee attacked him again. Appellant sustained severe injuries and required hospitalization.
The DC Circuit affirmed the district court's holding that Virginia's Workers' Compensation Act barred appellant's claim because his assault arose out of his employment. In this case, the manner in which appellant carried out his duties -- trying to help a customer -- motivated the employee's assault and thus his assault arose out of his employment.
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