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Pro-Football, Inc. v. Uhlenhake

558 S.E. 2d 571 (Va. App. 2002)

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Pro-Football, Inc. v. Uhlenhake

Virginia Court of Appeals
558 S.E. 2d 571 (Va. App. 2002)

Facts

Jeffrey Uhlenhake (plaintiff) was employed as an offensive lineman for Pro-Football, Inc. (defendant). Uhlenhake’s employment duties include training, practicing, and playing in football games. Uhlenhake sustained injuries to his left foot and knee while playing in a regularly scheduled game. Uhlenhake filed a claim with the Virginia Workers’ Compensation Commission (the commission) seeking disability benefits. The commission awarded Uhlenhake permanent partial-disability benefits for his foot injury but denied benefits for his knee injury. Both parties appealed the commission’s determination. Pro-Football argued that injuries sustained by professional football players were not compensable under the Virginia Workers’ Compensation Act because such injuries either result from voluntary activities or are foreseeable and therefore not accidental within the meaning of the act.

Rule of Law

Issue

Holding and Reasoning (Benton, J.)

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