Geathers v. 3V, Inc.

Martha Geathers (plaintiff) injured her back and leg while working for 3V, Inc. (defendant). Geathers returned to work a few weeks later, was placed on light duty for two months, and later returned to full duty after reaching maximum medical improvement and being released from her doctor’s care. A few months later, Geathers suffered another injury and was again placed on light duty. Geathers’s doctor indicated that the second injury aggravated conditions from her first injury. After two days of light duty, 3V sent Geathers home because there was no light-duty work for her. Geathers did not seek new employment. At the time of Geathers’s first injury, 3V’s workers’-compensation carrier was EBI Companies (EBI). When Geathers was injured the second time, Liberty Mutual Insurance Company (Liberty) was the carrier. The workers’-compensation commission ordered EBI to pay Geathers benefits for the period between the first and second accidents and ordered EBI and Liberty to share equally in all benefits after the date of the second accident. EBI appealed, and the circuit court found that the accidents were clearly distinguishable because Geathers’s need for benefits after the second accident was necessitated solely by the second accident. The appellate court reversed and reinstated the commission’s decision. EBI appealed.