Breakroom fall not compensable: Appeals court

An appeals court in Arizona on Thursday ruled that a call center employee failed to prove that the injuries he suffered from a fall while opening a breakroom refrigerator during his break was causally related to his employment.

In Michael Turner v. The Industrial Commission of Arizona, On Target Staffing LLC, Work First Casualty Co., the Court of Appeals of Arizona, Division One in Phoenix agreed with an Industrial Commission of Arizona decision that the fall was not proven to be compensable.

Michael Turner had asserted that the refrigerator door was to blame for his fall, testifying that “the door was stuck, and when he pulled the door to open it, the refrigerator moved toward him, knocking him over,” documents state. He also testified that employees and management knew the refrigerator door was hard to open, yet an Administrative Law Judge heard testimony from other witnesses denying that assertion.

The appeals court wrote that surveillance footage showed that his fall was not caused by the appliance getting stuck but by his grabbing the door to keep from falling. Two doctors also testified that Mr. Turner “had been at risk for such a fall due to his age, altered gait” from a previous injury “and medical history related to his left knee,” documents state.

The appeals court cited previous case law that determined a claimant in another, similar case could not prove work caused an injury “because the accident was not caused by the surroundings or conditions of the workplace, but instead was caused by ‘a degenerative condition which might have been brought to the acute stage by any one of a number of everyday motions, at home or at work.’”