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Lewis Hulbert MORGAN Jr. Claimant-Appellant
vs.
COLUMBIA HELICOPTERS INC. Employer and North River Insurance Company Surety Defendants-Respondents
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Issues:
Workers' compensation, alcohol, post-accident testing.
Case Summary:
Lewis Morgan appeals a state review board's decision that denies him workers' compensation benefits for injuries he claims were work related. Morgan was injured in two-car collision that killed the driver of the second-vehicle. Morgan admitted to drinking about a fifth of alcohol prior to the crash. A post-accident test indicated Morgan's Blood Alcohol Content was .20 percent. He later pled guilty to vehicular manslaughter. Hours before the crash, Morgan met with an associate to discuss some work-related issues. In his application for workers' compensation, Morgan claimed his injuries were work related.
Decision of lower jurisdiction:
The Idaho Industrial Commission ruled that Morgan was ineligible for workers' compensation benefits. The panel ruled that Morgan's drinking on the night of the accident was the proximate cause of the fatal accident and that his journey's that evening deviated from his normal work-related travels. Morgan now appeals.
Outcome:
Morgan loses. The Idaho Supreme Court affirmed the decision of the state's benefits review board.