Williams Construction Co. v. Garrison

Williams Construction Company (Williams) (defendant) employed Jesse R. Garrison, Jr. (plaintiff) as a bulldozer operator. On July 25, 1974, Garrison suffered injuries in a workplace accident. Garrison applied for and received workers’-compensation benefits including medical expenses and temporary-total-disability benefits. Garrison did not file a claim for permanent-partial-disability benefits. Garrison began experiencing dizzy spells after the accident, but Garrison’s doctor and Williams allowed Garrison to return to work without restrictions. Garrison worked for Williams for another four months before Williams laid him off in early December of 1974. Garrison subsequently began working for himself as a tree trimmer, which involved climbing tasks similar to what Garrison had performed at Williams. On December 28, 1974, Garrison was trimming a tree when he fell off a 40-foot ladder while holding a chainsaw. Garrison was severely injured in the fall. In 1976, Garrison sought to reopen his previous workers’-compensation claim. Garrison alleged that he fell from the ladder due to a dizzy spell, and he asserted that his injuries from his fall were therefore caused by a disability from his July accident. Williams was unable to contradict Garrison’s claim that the dizzy spell that caused his fall was related to the dizzy spells resulting from the July accident. However, Williams asserted that Garrison had acted recklessly and unreasonably by climbing a 40-foot ladder while experiencing dizzy spells and that this reckless and unreasonable conduct broke any causal relationship between the July accident and the fall. The Workmen’s Compensation Commission awarded benefits after finding that Garrison was permanently totally disabled as a result of the fall and that the fall was attributable to Garrison’s disability from the July accident. A trial court affirmed the commission’s award, and Williams appealed to the Maryland Court of Special Appeals.