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plaintifftrialseizure

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Vause v. Vause Farm Equipment Co., 233 N.C. 88, 63 S.E.2d 173

Facts

Robert C. Vause was the president and general manager of Vause Farm Equipment Company and also worked as an employee. On August 2, 1948, while driving a truck to service a tractor, he experienced an epileptic seizure, which caused him to lose consciousness and fall from the truck. The Industrial Commission found that his fall resulted in significant injuries, including a fracture and dislocation of his hip. However, the evidence indicated that the seizure was the sole cause of his injury, as he had parked the truck in a safe position before losing consciousness.

The record discloses that there were no signs of the car ‘being hit‘, and plaintiff testified: there were ‘no bruises or injuries about me other than the injury mentioned to my hip.

Issue

Did the plaintiff's injury arise out of and in the course of his employment, as required by the Workmen's Compensation Act?

The decisive question presented here is: Was there any evidence before the Industrial Commission upon which it could make a finding of fact that plaintiff was injured by an accident arising out of his employment?

Rule

Under the Workmen's Compensation Act, a personal injury must arise out of and in the course of employment, meaning there must be a causal connection between the injury and the employment.

The Workmen's Compensation Act expressly provides that a ‘personal injury‘ entitling an employee to an award of compensation ‘shall mean only injury by accident arising out of and in the course of the employment, and shall not include a disease in any form, except where it results naturally and unavoidably from the accident.

Analysis

The court analyzed the evidence and determined that the plaintiff's injury was solely caused by his epileptic seizure, which occurred after he had parked the truck in a safe position. The court found no evidence that the conditions of his employment contributed to the injury, as the plaintiff had taken precautions by stopping the truck and lying down before the seizure occurred. Therefore, the court concluded that the injury did not arise out of his employment.

Examining the evidence below in the light of the foregoing principles, it appears that the plaintiff while a student at State College years ago suffered a spine injury which since then has made him subject to epileptic convulsions at intermittent intervals.

Conclusion

The Supreme Court reversed the lower court's judgment, ruling that Vause's injuries were not compensable under the Workmen's Compensation Act because they did not arise out of his employment.

The judgment of the lower court is reversed.

Who won?

The Vause Farm Equipment Company, Inc. and Travelers Insurance Company prevailed because the Supreme Court found that the plaintiff's injuries were solely due to his pre-existing medical condition and not related to his employment.

The evidence here shows that the plaintiff felt the epileptic seizure coming on. He pulled the truck off the road, parked it, and lay down on the seat in a place of apparent safety, with all of the ordinary dangers of his employment suspended and in repose.

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