AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for
Jails, Prisons and Detention Facilities
Workers' Compensation
A prisoner cleaning
a fry hood in a food service area fell off a ladder, lost feeling in his
legs for several minutes, and experienced severe pain when he stood up.
For several days, he claimed, he had trouble walking and intense pain persisted
even when lying down. He filed an Eighth Amendment civil rights lawsuit
over what he claimed was inadequate treatment for his injuries, including
a delay in x-rays and refusal to perform an MRI to determine that he had
a broken back. The trial court dismissed, finding that the Inmate Accident
Compensation Act, 18 U.S.C. 4126(c), a workers' compensation scheme for
federal prisoners injured during the course of their prison employment,
is the exclusive vehicle by which a federal inmate may receive compensation
for injuries suffered during the course of prison employment. The federal
appeals court overturned that decision, holding that the statute did not
bar otherwise available claims just because the unconstitutional conduct
allegedly occurred during prison employment. Koprowski v. Baker, #14-5451,
2016 U.S. App. Lexis 8633, 2016 Fed. App. 111P (6th Cir.).
A prisoner serving
a sentence at a county jail in Mississippi suffered injuries while on a
work detail in a county work program under the supervision of the sheriff's
office. The county and the medical corporation that provided him with services
for his injuries sought to collect reimbursement for medical expenses from
a state public entity Workers' Compensation Trust that provides workers'
compensation for the county. A federal appeals court found that the prisoner
was not covered under workers' compensation as the county did not have
an enforceable contract to hire the prisoner which was a precondition for
coverage. Vuncannon v. United States, #12-60435, 2013 U.S. App. Lexis 5284
(5th Cir.).
Nurses at a county jail were held hostage
by inmates who escaped from their cells. During the recapture of the inmates,
one of the nurses was shot by police. The nurses sought to sue the county
and a private corporation that operated the jail, seeking damages. The
defendants argued that the nurses' exclusive remedy was workers' compensation,
so they could not sue. A Florida appeals court found that the nurses' claims
were entirely based on allegations of negligence, so that an intentional
torts exception to workers' comp exclusivity did not apply. Summary judgment
for the defendants was affirmed. Hunt
v. Corrections Corporation of America, #1D09-1260, 2010 Fla. App. Lexis
6661 (1st Dist.).
Correctional officers' claim that their employer
had negligently or intentionally failed to establish or enforce adequate
policies for their protection against wrongful conduct by prisoners was
not barred by the "exclusive remedies" provision of the Alabama
workers' compensation statute when the resulting damages were "purely
psychological," rather than physical injuries. Bullin v. Correctional
Medical Services, Inc., #2030573, 908 So. 2d 269 (Ala. Civ. App. 2004),
cert. denied, #1040346 (Ala. 2005). [N/R]
Alabama correctional officials did not violate
prisoner's rights by withholding part of the monetary benefits paid to
him for injuries suffered while participating in a work-release program,
and using that money to pay for part of the cost of the prisoner's incarceration.
The prisoner was not an "employee" within the meaning of the
state's workers' compensation statute, so that the protections of the statute
against garnishment or seizure of benefits awards did not apply. Further,
even if he had been interpreted to be an "employee," the benefits
were in lieu of wages, and therefore the seizure of them to pay for part
of the cost of incarceration was authorized under state law. Gober v. Alabama
Dept. of Corrections, No. 2020064, 871 So. 2d 838 (Ala. Civ. App. 2003).
[N/R]
Under state of Washington workers' compensation
statute, county jail inmate trusty was entitled to medical benefits as
a volunteer worker performing assigned duties without pay for injuries
suffered in the course of his job. In re Wissink, # 22113-0-III, 81 P.3d
865 (Wash. App. 2003). [N/R]
Exclusion of violent offenders, including
those convicted of armed robbery, from participation in "boot camp"
program which provided an opportunity for early release after engaging
in strenuous exercise, manual labor, substance abuse treatment, and counseling,
was not a violation of either equal protection or due process of law. Instead,
it was rationally related to a legitimate penal objective. "Violent
offenders" are not a "suspect" class, and there was no showing
that the distinction was intended to result in racial discrimination. Jones-El
v. Grady, No. 02-2406, 54 Fed. Appx. 856 (7th Cir. 2002). [N/R]
Workers' compensation total disability benefits
under Connecticut law could not be discontinued while claimant was incarcerated.
Laliberte v. United Security, Inc., No. 16631, 801 A.2d 783 (Conn. 2002).
[N/R]
Evidence supported administrative law judge's
determination that an employee's work as a prison guard was a contributing
factor to his fatal heart attack, entitling his widow to workers' compensation
death benefits. Doctor's testimony indicated that employee would not have
died when he did in the absence of the physical and mental stress he experienced
at work on the day of his fatal heart attack. Phillips Correctional Inst.
v. Yarbrough, No. A00A22265, 548 S.E.2d 424 (Ga. App. 2001). [N/R]
Arizona state statute exempting 50% of a
debtor's disposable income from attachment to satisfy child support obligations
did not apply to a prisoner's workers compensation disability benefits
since these benefits were not wages or salary and the prisoner was not
a debtor who needed a portion of his income for self-maintenance. Prisoner's
ex-wife, therefore, was entitled to the full amount of the prisoner's benefits
for child support in the absence of his successfully modifying the order
of support and assignment of benefits. Hanley v. Industrial Commission
of Arizona, #1 CA-IC 00-0085, 21 P.3d 856 (Ariz. App. 2001). [N/R]
Prisoner who claimed he was injured while
working at penitentiary laundry was entitled to a new hearing on his workers'
compensation claim because the hearing examiner's findings in denying claim
were contradicted by the "vast weight" of the evidence presented.
Sweets v. Workers' Safety & Compensation Division, #01-75, 42 P.3d
461 (Wyo. 2002). [N/R]
281:78 Idaho prisoner injured while performing
maintenance work duties at the facility she was incarcerated at did not
qualify as a "community service worker" entitled to workers'
compensation benefits under state law. Crawford v. Dept. of Correction,
991 P.2d 358 (Idaho 1999).
282:95 Wyoming inmate could not collect "loss
of earnings" workers' compensation benefits for pre- incarceration
work-related injury during the time he was incarcerated. Apodaca v. Workers'
Safety & Comp. Division, No. 97-148, 97-158, 977 P.2d 56 (Wyo. 1999).
254:29 Correctional officer not entitled
to workers' compensation for post-traumatic stress disorder caused by her
discovery of hanging body of prisoner who committed suicide. Pinkerton
v. State Ex Rel. WWSCD, 939 P.2d 250 (Wyo. 1997).
[N/R] Workers compensation was exclusive
remedy for county jail employee who claimed that she was subjected to contaminated
and inadequate air ventilation system. Cerka v. Salt Lake Co., 988 F.Supp.
1420 (D. Utah 1997).
245:78 Cooking instructor giving vocational
education to inmates was entitled to total temporary disability benefits
for mental injuries caused by witnessing fight between inmates in her class.
Jordan v. Central Piedmont College, 476 S.E.2d 410 (N.C. App. 1996).
239:165 Pennsylvania court rules that prisoner's
escape from custody while in work release program made him ineligible for
workers' compensation benefits when later injured on job he took while
attempting to avoid recapture. Graves v. Workmen's Compensation Appeal
Board (Newman), 668 A.2d 606 (Pa. Cmwlth. 1995).
Injuries suffered by inmate in fight with
another prisoner while being transported from work was compensable. State
Dept. of Justice, Inmate Injury Fund v. Spear, 767 P.2d 928 (Or. App. 1989).
Imprisonment of individual did not terminate
right to workers' comp benefits for disability. Re Injury to Spera, 712
P.2d 1155 (Wyo. 1987).