Mercy Logging, LLC v. Johnnie L. Odom

Court of Civil Appeals of Alabama

Escambia County | 104 So. 3d 908 | July 27, 2012


Snake-Bite Injuries Not Compensable

In December 2009, Johnnie L. Odom filed a lawsuit seeking benefits under the Alabama Workers' Compensation Act for injuries sustained from rattlesnake bites on his hands during his employment with Mercy Logging, LLC. He alleged these injuries left him permanently and totally disabled. Mercy Logging denied that Odom's injuries were compensable under the Act.

The trial court found the injuries compensable, holding that the rattlesnake bite arose from an occupational risk as the employees encountered snakes during their work in the woods. Mercy Logging appealed that decision. In July 2012, the Alabama Court of Civil Appeals reversed and remanded the judgment, ruling that Odom's injury did not arise out of his employment with Mercy Logging.

The court ruled that capturing a poisonous snake on a public roadway presented a risk that was personal to Odom and not sufficiently related to his employment to be considered an occupational hazard.

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