Scott v. Bodwell Chrysler Dodge, Inc.

Insurance Company

MADA Workers' Compensation Trust

Date Decided

December 20, 2019

Panel Members

Timothy Collier

David Hirtle

Tom Pelletier


Legal Causation


Knee Causation Positional Risk Causal Relationship

File Size

118 KB


Summary from the Troubh Heisler Attorneys

Scott was sales administrator at Bodwell who, for reasons unrelated to his work, had his right leg amputated above the knee. He used a wheelchair at work, but he attached his prosthetic leg when he used the nearby restroom, because his wheelchair would not fit in the room, and the wheelchair-accessible restroom was much farther away. On his way back from the restroom, his prosthetic leg “got caught” on a hallway carpet, causing him to fall and injure his left knee.

Bodwell denied the claim on grounds of “legal causation,” arguing that the work hallway was no more hazardous than a non-work hallway. Judge Knopf cited the Maine Supreme Court’s 1995 decision in Moore v. Pratt & Whitney and found legal causation, as the closest restroom was not accessible to Scott’s wheelchair, requiring him to use his prosthesis instead. In addition, the injury occurred toward the end of Scott’s workday, when he was presumably hurrying to accommodate his customers.

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