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Leotha Faulkner v. Aramark Educational Services, Inc.

Decision date: October 30, 201316 pages

Summary

The Missouri Court of Appeals reversed the LIRC's initial award allowing compensation, and the LIRC issued a final award denying the employee's claim for workers' compensation benefits. The employee failed to provide timely written notice of her January 29, 2010 work-related right knee injury within the statutory 30-day requirement and could not prove the employer was not prejudiced by the delay.

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Caption

FINAL AWARD DENYING COMPENSATION (After Mandate from the Missouri Court of Appeals for the Eastern District)
Injury No.:10-026257
Employee:Leotha Faulkner
Employer:Aramark Educational Services, Inc.
Insurer:Indemnity Insurance Company of North America
Additional Party:Treasurer of Missouri as Custodian of Second Injury Fund (Open)
On September 3, 2013, the Missouri Court of Appeals, Eastern District, issued an opinion reversing the December 6, 2012, award and decision of the Labor and Industrial Relations Commission (Commission).Aramark Educational Services, Inc., et al. v. Leotha Faulkner, ED99439 (September 3, 2013). By mandate dated September 25, 2013, the Court confirmed its decision to reverse the Commission’s award and remanded this matter to the Commission with directions to set aside the Commission’s award of December 6, 2012, and enter, in lieu thereof, an order denying compensation benefits in accordance with the Court’s opinion delivered September 3, 2013.
Pursuant to the Court’s mandate, we issue this award. Our prior award and decision of December 6, 2012, is hereby set aside. Employee’s claim for compensation is denied because employee failed to proffer substantial and competent evidence to meet her burden of proving employer was not prejudiced by her failure to provide timely notice pursuant to § 287.420 RSMo.Given at Jefferson City, State of Missouri, this 30th day of October 2013.LABOR AND INDUSTRIAL RELATIONS COMMISSION
John J. Larsen, Jr., Chairman
James G. Avery, Jr., Member
Curtis E. Chick, Jr., Member
Attest:

FINAL AWARD ALLOWING COMPENSATION

(Reversing Award and Decision of Administrative Law Judge)

Injury No.: 10-026257

Employee: Leotha Faulkner

Employer: Aramark Educational Services, Inc.

Insurer: Indemnity Insurance Company of North America

Additional Party: Treasurer of Missouri as Custodian of Second Injury Fund (Open)

This cause has been submitted to the Labor and Industrial Relations Commission (Commission) for review as provided by $\S 287.480 RSMo. { }^{1}$ We have reviewed the evidence and briefs, heard oral argument, and considered the whole record. Pursuant to $\S 286.090$ RSMo, the Commission reverses the award and decision of the administrative law judge (ALJ) dated April 17, 2012.

Preliminaries

On January 29, 2010, employee injured her right knee in a work fall. The ALJ denied employee's claim for temporary total disability benefits and permanent partial disability benefits because he found that employee failed to provide employer with proper, timely notice and failed to prove that employer was not prejudiced as a result of her failure to provide said notice.

Findings of Fact

The findings of fact and stipulations of the parties were accurately recounted in the award of the ALJ and, to the extent they are not inconsistent with the findings listed below, they are adopted and incorporated by the Commission herein.

Discussion

The only issue before the Commission is whether employee provided employer with proper notice of her January 29, 2010, work injury.

Section 287.420 RSMo provides, in relevant part:

No proceedings for compensation for any accident under this chapter shall be maintained unless written notice of the time, place and nature of the injury, and the name and address of the person injured, has been given to the employer no later than thirty days after the accident, unless the employer was not prejudiced by failure to receive the notice.

Written notice is not required if the claimant can prove that the employer had actual knowledge of the accident or the employer was not prejudiced by the claimant's failure to report the accident within the statutory time period. Soos v. Mallinckrodt Chem. Co.,

[^0]

[^0]: ${ }^{1}$ Statutory references are to the Revised Statutes of Missouri 2009 unless otherwise indicated.

19 S.W.3d 683, 686 (Mo. Ct. App. 2000), overruled on other grounds, Hampton v. Big Boy Steel Erection, 121 S.W.3d 220 (Mo. banc 2003).

In this case, employee concedes that she failed to provide proper, timely notice under $\S 287.420$ RSMo. Employee's only argument on appeal is that employer was not prejudiced by her failure to do so. In support of said argument, employee points to the fact that employer stipulated to every factual issue in this case that could speak to compensability. Therefore, employee argues, the evidence she is statutorily required to provide with respect to proving a lack of prejudice was provided by stipulation in this matter.

In response to employee's contention that no prejudice resulted from her failure to provide proper notice, employer raises numerous arguments alleging that it was, in fact, prejudiced.

Employer argues that it was prejudiced in that it was unable to timely investigate the accident to determine causation and address safety issues. Specifically, employer argues that because it was unable to timely investigate the accident, 1) it does not know if employee breached her duty (as provided in employer's policies) to wear non-slip footwear; 2) it was unable to secure the scene of the accident and address the injury at its safety meetings; and 3) it was prevented from providing employee with proper medical treatment.

Employer stipulated that the injury occurred when and how employee alleges, and that as a result of the accidental work injury employee sustained 20\% permanent partial disability of the right knee. By stipulation, employer concedes that employee's injury on January 29, 2010, arose out of and in the course of her employment. If employer believed that causation was an issue in question, it should not have stipulated to that issue at the hearing. Further, if employer believed that employee failed to wear her non-slip footwear in violation of its safety rules, it needed to plead the same as an affirmative defense under § 287.120.5 RSMo. See Carver v. Delta Innovative Services, 2012 Mo. App. LEXIS 1123 (Mo. App. Sept. 11, 2012).

Employer argues that it only stipulated to the aforementioned because it had no evidence to contradict employee's version of the facts, but argues that it is because of employee's failure to provide timely notice that it was unable to timely investigate the accident to obtain said contradictory evidence. We do not find this argument persuasive. It is employee's burden to prove her entitlement to compensation. If employer questioned the circumstances surrounding how the accident occurred, it should not have stipulated to every fact concerning the same.

With respect to employer's contention that it was prejudiced by its inability to secure the scene of the accident and address the injury at its safety meetings, we find that employer has pointed out the potential for prejudice, but did not point to actual prejudice as a result of employee's untimely notice. If another individual was injured in the same location that employee was injured and employer could have prevented said injury had employee provided proper notice, this would represent prejudice. However, employer is merely pointing to the possibility that it could have suffered prejudice due to employee's untimely notice and we do not find this argument persuasive.

As mentioned above, employer also argues that its inability to timely investigate the accident prevented it from providing proper medical treatment. Employer stipulated that as a result of the work injury employee sustained 20% permanent partial disability of the right knee. Employee does not seek reimbursement for her past medical expenses, nor does she request future medical care. In light of the foregoing, we fail to see how employer was prejudiced by its failure to direct and provide employee's medical treatment.

Based upon the foregoing, and in light of employer's stipulations, we do not find that employer was prejudiced by its inability to timely investigate the accident and provide medical treatment.

In addition to the aforementioned, employer argues that it was prejudiced by employee's untimely notice because it caused employer to breach its contract with Washington University. While employer does not point to any adverse action actually taken by Washington University with regard to this accident, employer contends that Washington University could have terminated the contract with employer due to employer's failure to provide it with timely notice of the accident. Similar to employer's argument that it was prejudiced by its inability to address the accident in its safety meetings, employer has only pointed out the possibility of it suffering prejudice due to employee's untimely notice, but has not pointed to any actual prejudice suffered as a result of the same. Further, the contract between Washington University and employer was not entered into evidence, which makes it very difficult to determine what, if any, provisions were breached as a result of employee's untimely notice.

We find, based upon the totality of the evidence, that employee met its burden of proving that employer was not prejudiced by her failure to report the accident within the statutory time period.

Award

We reverse the ALJ's award and find that while employee failed to provide employer with timely notice of her accident, employee met her burden of proving that employer did not suffer any prejudice as a result of the same.

In accordance with the parties' stipulations and the findings herein, employee is awarded, and employer is ordered to pay: 1) $76 / 7$ weeks of temporary total disability benefits from April 8, 2010, through June 2, 2010, or \$1,895.06; and 2) 20\% permanent partial disability benefits rated at the right knee, or $\ 7,718.08.

Sam W. Eveland, attorney for employee, is allowed a fee of 25 % of all sums awarded under the provisions of this award for necessary legal services rendered to employee. The amount of this attorney's fee shall constitute a lien on the compensation awarded herein.

Any past due compensation shall bear interest as provided by law.

The award and decision of Administrative Law Judge John K. Ottenad, issued April 17, 2012, is attached and incorporated to the extent it is not inconsistent with this final award.

Given at Jefferson City, State of Missouri, this $6^{\text {th }}$ day of December 2012.

LABOR AND INDUSTRIAL RELATIONS COMMISSION

V A C A N T

Chairman

James Avery, Member

Curtis E. Chick, Jr., Member

Attest:

Secretary

AWARD

Employee:Leotha FaulknerInjury No.: 10-026257
Dependents:N/ABefore the
Employer:Aramark Educational Services, Inc.Division of Workers'
Additional Party: Second Injury Fund (Open)
Department of Labor and Industrial
Relations of Missouri
Insurer:Indemnity Insurance Company of NorthJefferson City, Missouri
America C/O Sedgwick Claims Management Services
Hearing Date:January 11, 2012Checked by: JKO

FINDINGS OF FACT AND RULINGS OF LAW

  1. Are any benefits awarded herein? No
  2. Was the injury or occupational disease compensable under Chapter 287? No
  3. Was there an accident or incident of occupational disease under the Law? Yes
  4. Date of accident or onset of occupational disease: January 29, 2010
  5. State location where accident occurred or occupational disease was contracted: St. Louis County
  6. Was above employee in employ of above employer at time of alleged accident or occupational disease? Yes
  7. Did employer receive proper notice? No
  8. Did accident or occupational disease arise out of and in the course of the employment? Yes
  9. Was claim for compensation filed within time required by Law? Yes
  10. Was employer insured by above insurer? Yes
  11. Describe work employee was doing and how accident occurred or occupational disease contracted: Claimant was employed as a custodian for Employer, when she slipped and fell on black ice, injuring her right knee.
  12. Did accident or occupational disease ca

Full decision text continues in the plain-text archive copy.

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