Ex parte Patsy Patton d/b/a Korner Store

Supreme Court of Alabama

Bibb County | 77 So.3d 591 | April 22, 2011


"But-for" Test Overruled - Conflicts with Plain Language of the Act

This case revolves around a worker at a convenience store, Lana T. Brown, who filed a claim for workers’ compensation benefits following a fall at work which resulted in a broken wrist. The claim was denied by her employer, Patsy Patton d/b/a Korner Store, stating the fall was not work-related and could, therefore, be classified as either idiopathic or due to an unexplained cause.

In the lower court, a summary judgment was given in favor of Korner Store, an action which Brown appealed. Subsequently, the Court of Civil Appeals reversed the decision, remanding the case for further proceedings. This led Korner Store to petition for a writ of certiorari to the Supreme Court of Alabama.

The Supreme Court reversed the judgment of the Court of Civil Appeals and awarded judgment in favor of Korner Store. The court ruled that the supposed "but-for" test for causation in workers’ compensation cases conflicted with the plain language of the Act, thus overruling previous decisions implying otherwise.

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