Powers v. District of Columbia Department of Employment Services
566 A.2d 1068, 1989 D.C. App. LEXIS 272, 1989 WL 146323 (1989)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under the D.C. Workers' Compensation Act, an employee who voluntarily resigns from light-duty employment (where they are earning pre-injury wages) for economic reasons to take a higher-paying job is not eligible for workers' compensation benefits for subsequent wage loss, as such a resignation severs the causal link between the injury and the claimed disability.
Facts:
- Powers suffered a back injury while working for the National Geographic Society.
- The back injury prevented Powers from performing all the duties required by his old job.
- The National Geographic Society retained Powers in a light-duty job at his former wage level.
- Several months later, Powers voluntarily resigned from the National Geographic Society.
- Powers resigned to take a higher-paying job with the U.S. Postal Service.
- After a few weeks, Powers quit the U.S. Postal Service job because its duties were too difficult for his injured back.
- The National Geographic Society refused to rehire Powers after he left the Postal Service.
- It took Powers about five months to find new employment after leaving the Postal Service.
Procedural Posture:
- Powers filed a claim for workers’ compensation benefits covering a five-month period following his unemployment, with the Department of Employment Services (DOES).
- The Director of the Department of Employment Services (DOES) denied Powers' claim.
- Powers appealed the Director's decision to the District of Columbia Court of Appeals.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is an employee who sustains a work-related injury, continues to receive pre-injury wages in a light-duty role, and then voluntarily resigns to seek higher-paying employment, eligible for workers' compensation benefits if their subsequent job causes a new inability to work related to the initial injury?
Opinions:
Majority - Steadman, Associate Judge
No, an employee who voluntarily resigns from light-duty employment where they are earning pre-injury wages, for economic reasons to take a higher-paying job, is not eligible for workers' compensation benefits for subsequent wage loss. The D.C. Workers' Compensation Act defines 'disability' as incapacity resulting in a 'loss of wages.' At the time Powers resigned from the National Geographic Society, he was receiving the same wages as before his injury, and therefore was suffering no 'loss of wages' due to the injury. The Director of the Department of Employment Services (DOES) correctly determined that Powers' voluntary departure for a better-paying job, which entailed a risk of wage diminution, constituted a voluntary limitation of income that severed the causal link between his injury and any subsequent wage loss. The court affirmed the Director's decision, emphasizing that an agency's interpretation of a statute it administers is binding unless it conflicts with the plain meaning or legislative history, and the Director's interpretation was reasonable and consistent with precedent from other jurisdictions.
Analysis:
This case clarifies the limitations on workers' compensation benefits when an injured employee voluntarily changes jobs for economic reasons. It establishes that a claimant's ability to receive pre-injury wages in an accommodating role effectively negates a 'loss of wages' due to injury, and a subsequent voluntary resignation for better pay severs the causal chain needed for compensation. The ruling reinforces judicial deference to agency interpretations of statutes they administer, particularly within the specialized area of workers' compensation law. This precedent may encourage employees to carefully consider the implications of voluntary job changes post-injury, as such actions can preclude future compensation for conditions related to the original injury.
