## Facts

- Jeffrey A. Uhlenhake, a professional football offensive lineman employed by Pro-Football, Inc., sought workers’ compensation benefits for alleged work-related injuries to his left foot/ankle and left knee sustained during regular season games.
- Before joining the employer, Uhlenhake had left-knee ACL reconstruction surgery (1993) and later reported some knee clicking; he also had bursa-related complaints shortly before the alleged knee injury.
- On September 28, 1997, during a scheduled game, another player fell on Uhlenhake’s left ankle/foot; he reported it to the team trainer, continued playing, and later was examined by the team physician, who noted an ankle sprain with swelling, bruising, and pain.
- On November 9, 1997, during another scheduled game, Uhlenhake felt a pop and pain in his left knee while blocking and described twisting or hyperextension; he continued playing, reported it the next day, and sought treatment for significant swelling.
- The Virginia Workers’ Compensation Commission awarded permanent partial disability benefits for the left foot injury but denied benefits for the left knee claim.
- The employer appealed, arguing professional football injuries are not covered (voluntary/foreseeable) and that the evidence did not support the foot award; Uhlenhake cross-appealed the knee denial.

## Issues

1. Whether injuries suffered by a professional football player during regular games are excluded from coverage because they are voluntary or foreseeable and therefore not an “injury by accident” under the Virginia Workers’ Compensation Act.
2. Whether credible evidence supported the Commission’s finding of a compensable left foot/ankle injury by accident and resulting permanent partial disability.
3. Whether the Commission erred in denying benefits for the claimed left knee injury by accident allegedly occurring on November 9, 1997.

## Decision

- The Court of Appeals of Virginia affirmed the Commission in full.
- The court rejected a categorical rule excluding professional football injuries from the Act based on voluntariness or foreseeability.
- The court held credible evidence supported the Commission’s award for the September 28 left foot/ankle injury and permanent partial disability.
- The court held credible evidence supported the Commission’s denial of benefits for the alleged November 9 left knee injury, including the Commission’s causation findings in light of preexisting knee conditions.

## Legal Principles

- An “injury by accident” under the Virginia Workers’ Compensation Act requires an identifiable incident at a reasonably definite time causing a sudden mechanical or structural change in the body, arising out of and in the course of employment.
- The inherent or foreseeable risks of a job, including professional sports, do not by themselves defeat compensability if the statutory elements of an injury by accident are met.
- On appeal, the Commission’s factual findings (including causation, disability, and weight of medical evidence) are binding if supported by credible evidence; the appellate court does not reweigh evidence or reassess witness credibility.

## Conclusion

The court held that professional football players are not categorically excluded from Virginia workers’ compensation coverage and affirmed the Commission’s determination that an identifiable game incident supported compensability and permanent partial disability for the left foot injury, while the claimant failed to prove a compensable left knee injury given the evidence on causation and preexisting conditions.


Pro-Football, Inc. v. Uhlenhake, 558 S.E.2d 571 (Va. Ct. App. 2002)