Chaney v. Team Technologies, Inc.Annotate this Case
The Supreme Court reversed the order of the trial court denying Employer’s motion to dismiss Employee’s action seeking workers’ compensation benefits for injuries she received from Employer’s failure to use its automated external defibrillator (AED) while Employee suffered a non-work related medical emergency, holding that Employer was not liable for workers’ compensation benefits under the circumstances.
Employee collapsed at work because of a medical condition unrelated to her employment. Employer had acquired an AED but did not use it to assist Employee while awaiting emergency medical responders. Employee brought suit, alleging that Employer’s failure to use the AED and its failure to train or hire an employee able to use an AED delayed resuscitation efforts, causing Employee to sustain a brain injury. The trial court denied Employer’s motions to dismiss. The Supreme Court reversed, holding that Employee’s claim did not arise out of her employment because Employer provided reasonable medical assistance and had no statutory or common law duty to use its AED to assist Employee.
Authoring Judge: Justice Sharon G. Lee
Trial Court Judge: Judge Thomas J. Wright
The issue in this interlocutory appeal is whether an employer, who did not use an automated external defibrillator (AED) to assist an employee who suffered a non-work related medical emergency, can be liable for workers compensation benefits. An employee collapsed at work because of a medical condition unrelated to her employment. The employer knew of the employee s need for immediate medical assistance. The employer had acquired an AED but did not use it to assist the employee while awaiting the arrival of emergency medical responders. Medical responders assisted the employee, but she suffered a brain injury because of oxygen deprivation. We hold that an injury that is caused by an employer s failure to provide reasonable medical assistance arises out of and in the course of employment when an employee becomes helpless at work because of illness or other cause unrelated to her employment, the employee needs medical assistance to prevent further injury, the employer knows of the employee s helplessness, and the employer can provide reasonable medical assistance but does not do so. Here, the employee s claim did not arise out of her employment because her employer provided reasonable medical assistance and had no statutory or common law duty to use its AED to assist the employee. Therefore, the employer is not liable for workers compensation benefits. We reverse the trial court s denial of the employer s motion to dismiss and remand to the trial court for an order of dismissal.