Squeo v. Comfort Control Corp.

Eugene Squeo (plaintiff) became paralyzed at age 25 after falling from a roof while working for Comfort Control Corporation (Comfort Control) (defendant). Squeo received compensation for total permanent disability. Squeo suffered many physical and psychological setbacks after the accident and attempted suicide three times while living in a nursing home. Squeo’s doctor explained that Squeo had previously lived independently and that the nursing-home environment caused Squeo to experience depression and frustration that could lead Squeo to attempt suicide again. Doctors and others who knew Squeo believed that Squeo’s psychological issues could be relieved only if Squeo lived independently. Squeo subsequently sought a modification of the compensation award that would require Comfort Control to construct a self-contained apartment attached to Squeo’s parents’ home. Squeo’s proposed apartment cost over $65,000 and included a bedroom, kitchen, living room, bathroom, carport, basement, and hydraulic lift. The compensation court ordered the construction but said that Squeo needed to pay for any construction beyond a standard room-and-bathroom addition to his parents’ home. The New Jersey Appellate Division affirmed the compensation court’s order and instructed that the apartment’s cost should not exceed what would be required for Squeo to have basic independent living quarters. Comfort Control appealed to the New Jersey Supreme Court, arguing that the construction of a self-contained apartment went beyond the scope of compensable benefits under New Jersey’s workers’-compensation statute.