Total Fire Protection, Inc. v. Jean

Court of Civil Appeals of Alabama

Jefferson County | 160 So. 3d 795 | Aug. 22, 2014


Last-Injurious-Exposure Rule and Termination of Benefits: Total Fire Protection, Inc. v. Jean Case Review

The case Total Fire Protection, Inc. v. Jean, in the Alabama Court of Civil Appeals challenged the employer's move to terminate its medical benefits being paid to a former employee – Jonathan Jean, after he changed jobs and was diagnosed with Carpal Tunnel Syndrome. 

The worker had previously been compensated following a fall and the settlement approved by the court meant that he was entitled to future medical benefits. The employer filed to terminate these benefits on the grounds that the worker's carpal tunnel syndrome was due to his new job. The court however, affirmed the judgment of a lower court in denying the employer's motion to terminate the benefits, stating that the worker's right to future medical treatment could only be extinguished through procedures set out in the Alabama Workers' Compensation Act (the Act), and not via a postjudgment motion. 

The court held that the employer's claim that the last-injurious-exposure rule applies, thereby relieving it of liability for further medical benefits, was incorrectly applied. Rather, they stated that the rule actually requires the employer to continue rendering the medical treatment, as the worker's wrist pain should be treated as a recurrent symptom from the original injury and not as an aggravation of the injury due to working at a different job.

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