Dillard v. Calvary Assembly of God

Court of Civil Appeals of Alabama

Morgan County | No. 2210341 | Sept. 23, 2022


Dillard’s Appeal Denied: Court Upholds Calvary’s Time-Barred Defense on Workers’ Compensation Claim Due to Misapplication of the Latent-Injury Exception

Ron Dillard, an employee of Calvary Assembly of God, sustained a back injury on September 20, 2017, and sought workers' compensation benefits, claiming he was unaware of the compensable nature of his injury until after surgery in March 2020. Calvary Assembly of God contested the claim, arguing it was time-barred by a two-year statute of limitations. Dillard invoked the latent-injury exception, claiming unawareness of his injury’s serious and compensable nature until after his March 2020 surgery. However, the court ruled that this exception didn’t apply as Dillard was, or should have been, aware of the compensable nature of his injury when surgery was recommended in December 2017, rendering his September 2020 claim out-of-date. The trial court’s initial judgment in favor of Calvary was upheld, and Dillard’s appeal for his postjudgment motion was denied.

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