Georgia Supreme Court Considers Scope of Compensability in Wokers’ Compensation Cases

In the case of Frett v. State Farm Employee Workers' Compensation, the Supreme Court of Georgia addressed the issue of whether a workers' compensation claimant, Ms. Rochelle Frett, was entitled to workers’ compensation benefits after an injury sustained at work.  A central question considered by the Supreme Court was whether the trial court correctly interpreted and applied workers' compensation laws and prior precedent to Ms. Frett’s case.

Rochelle Frett was employed by State Farm Insurance and injured her back at work after she slipped and fell during her scheduled lunch break.  She filed for workers’ compensation benefits after sustaining the subject injury.  State Farm’s workers' compensation insurer contested the claim, asserting that Ms. Frett’s injury was not compensable under the Georgia Workers' Compensation Act due to it occurring not technically while she was working, but during a break.

The lower court initially ruled in favor of Ms. Frett’s employer, State Farm, and rejected Ms. Frett’s claim for compensation.  The court came to the conclusion that Ms. Frett had not met the necessary legal requirements to establish that her injury was compensable as defined by the Georgia Workers' Compensation Act.  Specifically, the court found that the injury was not within the scope of employment as defined by Georgia law due to it occurring during a lunch break and not directly when Ms. Frett was working.

Ms. Frett appealed the initial decision.  The Court of Appeals upheld the initial decision and relied on the precedent of Ocean Acc. & Guar. Corp. v. Farr, 180 Ga. 266 (178 SE 728) (1935), ruling that Ms. Frett was not entitled to workers’ compensation benefits due to the fact that her injury occurred during a scheduled break and as a result did not arise from her employment.

Ms. Frett continued to appeal the decision, and the Georgia Supreme Court reviewed the case and the lower court’s decision.  The Supreme Court weighed on the issue of whether or not Ms. Frett’s back injury was work-related or arose out of the scope of her employment since it occurred during her lunch break. 

The Supreme Court ultimately reversed the decision of the trial court and the Court of Appeals, holding that the evidence presented by Plaintiff was sufficient to establish that her injury occurred during the course of employment and was compensable under the Georgia Worker’s Compensation Act.  The Court overruled Ocean Acc. & Guar. Corp. v. Farr, 180 Ga. 266 (178 SE 728) (1935) and reversed the decisions of the trial court and Court of Appeals, emphasizing that the rules of compensability of injuries under the Georgia Worker’s Compensation Act must be interpreted so that its purpose is fulfilled in offering workers fair compensation for injuries sustained while at work.  The Court found that, while the injury occurred during a lunch break, it still happened while Ms. Frett was at work. 

This ruling from the Supreme Court provided further and new guidance of how the Georgia Workers’ Compensation Act is to be interpreted, overturning former precedent.  This decision will change how Worker’s Compensation cases are adjudicated in the future in Georgia, potentially leading to increased liability on employers for injuries that occur during lunch breaks or other employee breaks.

Topic/Tags: Workers’ Compensation