## Facts

- Vernell Harris worked for the Howard County Board of Education as a food service assistant at a high school, performing tasks such as preparing lunches, operating a cash register, cleaning, and laundering linens.
- Her job regularly involved lifting and moving heavy items, including boxes of frozen food and laundry supplies.
- On January 25, 1999, Harris and a coworker opened a large box of laundry detergent and found it contaminated with cockroaches; they closed it and dragged the heavy box outside to prevent contamination.
- While bending to tie up the detergent bag, Harris felt a “crack” in her back and experienced immediate pain.
- Medical evidence supported that the back injury resulted from dragging the box and the related movements.
- Harris filed a workers’ compensation claim alleging an accidental personal injury arising out of and in the course of employment; the Workers’ Compensation Commission awarded benefits.
- On the employer’s judicial review, the circuit court instructed the jury that compensability required “unusual activity” (a departure from ordinary work), and the jury found for the employer; the intermediate appellate court affirmed.

## Issues

1. Whether an “accidental personal injury” under Maryland workers’ compensation law requires that the injury result from “unusual activity,” rather than from routine job duties.
2. Whether an unexpected injury suffered during usual work activities can qualify as an “accidental” injury arising out of and in the course of employment.

## Decision

- The Court of Appeals of Maryland reversed the judgment for the employer and remanded for proceedings consistent with its interpretation of the statute.
- The court held the Workers’ Compensation Act does not impose an “unusual activity” requirement for accidental personal injury.
- The court overruled prior Maryland decisions that had injected an “unusual activity” condition into the definition of accidental injury.
- Applying the correct standard, Harris’s back injury could be compensable because the injury was unexpected and occurred in the course of her employment duties.

## Legal Principles

- The statutory definition of “accidental personal injury” in Maryland workers’ compensation law does not require the work activity to be unusual or extraordinary.
- “Accidental” refers to the injury as an unexpected or unintended result; routine work activity may still produce an accidental injury.
- Compensability requires that the injury arise out of and in the course of employment and not fall within an express statutory exclusion.
- Courts may not narrow workers’ compensation coverage by adding judge-made requirements inconsistent with statutory text and the Act’s remedial purpose.

## Conclusion

Maryland’s highest court rejected an “unusual activity” test for accidental personal injury, holding that an unexpected injury arising during ordinary work can be compensable if it arises out of and in the course of employment.


Harris v. Bd. of Educ. of Howard Cnty., 825 A.2d 365 (Md. 2003)