Haynes v. R.B. Rice, Division of Sara Lee

Craig F. Haynes (plaintiff) was employed by R. B. Rice, Division of Sara Lee (defendant). On April 19, 1986, Haynes was injured at work. Haynes was addicted to cocaine, and in the weeks surrounding his workplace injury, Haynes overdosed twice. On the night before his injury, Haynes injected one and one-half grams of cocaine and drank four to six beers. Haynes did not eat dinner or breakfast and did not sleep that night. On the morning of his injury, Haynes was driven to work by a friend. One of Haynes’s coworkers, James Jamison, had to carry Haynes back to the car because Haynes kept falling down and was unable to walk. Jamison testified that Haynes appeared to be out of his mind. Haynes eventually made it into work. Haynes was responsible for cleaning metal chili tubs with very hot water, which he did alone in the chili room. About an hour and a half to two hours into Haynes’s workday, Haynes was found lying unconscious on the floor with scalding water spraying onto his body. None of the chili tubs had been rinsed out. No one witnessed Haynes’s fall. Haynes, who suffered severe burns to several parts of his body, filed a claim for workers’-compensation benefits. At his hearing, Haynes testified that he did not remember what had happened. Dr. Oxley, a board-certified pathologist, testified that the amount of cocaine found in Haynes’s blood after the accident would have made it impossible for Haynes to perform his work duties. The Labor and Industrial Relations Commission (the commission) denied Haynes’s claim, finding that the fall was not work related. The commission determined that the fall was idiopathic and related to Haynes’s cocaine use. Haynes appealed.