## Facts

- Michael G. Blakeslee, Jr. worked for Platt Brothers & Co.
- While at work, he suffered a grand mal seizure, fell near workplace equipment, and lost consciousness.
- After regaining consciousness, he began flailing his arms and legs in a manner perceived as dangerous to himself and others.
- Three coworkers restrained him to prevent further injury and to control the situation at the workplace.
- During the restraint, Blakeslee dislocated both shoulders and later required surgery.
- Medical evidence supported that the shoulder injuries were caused by the coworkers’ restraint rather than by the seizure itself.
- The workers’ compensation commissioner found the seizure was a noncompensable personal medical event and that the seizure set the causal sequence in motion, but also found the shoulder injuries were caused by coworkers’ intervention.
- The commissioner dismissed the claim; the Compensation Review Board affirmed; the Connecticut Supreme Court reviewed the case after transfer from the Appellate Court.

## Issues

1. Whether injuries caused by coworkers restraining an employee after a noncompensable seizure at work “arose out of and in the course of” employment under the Connecticut Workers’ Compensation Act.

## Decision

- The Connecticut Supreme Court reversed the Compensation Review Board.
- The Court held that Blakeslee’s shoulder injuries arose out of and in the course of employment, despite the seizure itself being noncompensable.
- The Court remanded with direction to award workers’ compensation benefits for the shoulder injuries.
- A dissent would have affirmed, reasoning the causal chain began with a noncompensable personal condition.

## Legal Principles

- An injury “arises out of” employment when there is a causal connection between the employment and the injury through the activities, conditions, or environment of employment.
- A noncompensable personal medical event occurring at work does not automatically bar compensation for distinct injuries proximately caused by an employment-related risk or occurrence.
- Coworker aid or rescue efforts responding to an on-the-job emergency can be treated as an incident of employment when undertaken for the mutual benefit of employee and employer.
- An intervening employment-related act may supply the required causal connection even if the precipitating medical event is personal and noncompensable.

## Conclusion

The court held that shoulder injuries caused by coworkers’ workplace restraint in response to an employee’s seizure were compensable because the restraint was an employment-related intervention undertaken in an on-the-job emergency, satisfying the “arising out of and in the course of employment” requirement even though the seizure itself was not compensable.


Blakeslee v. Platt Bros. & Co., 279 Conn. 239, 902 A.2d 620 (Conn. 2006)