Stovall v. Sally Salmon Seafood

Pamela R. Stovall (plaintiff) worked for Sally Salmon Seafood (Sally Salmon) (defendant) for about a year, until June 5, 1984. At Sally Salmon, Stovall shook crab, which required her to strike her wrist against a pan or bench. Stovall’s work caused pain and swelling in her wrist. Stovall did not miss work, seek medical treatment, or leave her job because of her wrist. In July 1984, Stovall applied for a job at Hallmark Fisheries (Hallmark) (defendant). On her application, Stovall denied ever experiencing hand, wrist, or arm trouble. At Hallmark, Stovall was a black-cod scraper. After two weeks on the job, Stovall began experiencing pain and swelling in her wrist and hand. In September, Stovall was diagnosed with carpal tunnel syndrome and sought workers’-compensation benefits. Both Sally Salmon and Hallmark conceded the claim was compensable, but each argued that the other was responsible. Hallmark argued that Stovall was estopped from claiming benefits from Hallmark because Stovall falsely stated that she did not have hand, wrist, or arm trouble on her application. At the hearing, the Hallmark plant supervisor testified that if Stovall had truthfully answered the question, Hallmark would not have hired her for that position. The referee found that Sally Salmon was responsible for the claim. The Workers’ Compensation Board found that Hallmark was responsible under the last-injurious-exposure rule. The court of appeals affirmed the decision of the Workers’ Compensation Board, stating that even if equitable estoppel applied to workers’-compensation cases, it would not apply to the facts here.