## Facts

- Jesse R. Garrison, Jr. worked for Williams Construction Company, Inc. as a bulldozer operator.
- On July 25, 1974, Garrison fell from a pusher-tractor and injured his back in the course of employment.
- The Maryland Workmen’s Compensation Commission accepted the claim as compensable; the insurer paid temporary total disability and medical benefits.
- After the work accident, Garrison experienced intermittent dizzy spells noted by his treating physician.
- Garrison was released to return to work without restrictions and resumed his prior job; he later was laid off on December 6, 1974.
- Garrison then worked for himself as a tree trimmer.
- On December 28, 1974, while trimming a tree, Garrison climbed a 40-foot ladder carrying a chainsaw and fell, sustaining severe injuries.
- In late 1976, Garrison sought to reopen the workers’ compensation claim, asserting the ladder fall was caused by a dizzy spell attributable to the July 1974 work injury.
- On August 9, 1977, the Commission awarded additional temporary total disability and permanent total disability, attributing the December 1974 injuries to the original compensable injury.
- The circuit court affirmed the Commission by granting summary judgment for Garrison.

## Issues

1. Whether Garrison’s December 28, 1974 injuries and resulting permanent total disability were proximately caused by the July 25, 1974 compensable work injury as a subsequent injury.
2. Whether Garrison’s conduct in climbing a 40-foot ladder while experiencing dizzy spells constituted willful misconduct or a superseding intervening cause that broke the causal chain and defeated compensability.

## Decision

- The Court of Special Appeals of Maryland affirmed the circuit court’s summary judgment for Garrison.
- The court held the later injuries were a natural consequence of dizziness stemming from the original compensable injury, supporting proximate causation.
- The court held Garrison’s ladder-climbing did not rise to willful misconduct or otherwise break the causal chain.
- The Commission’s awards of additional temporary total disability and permanent total disability benefits remained in effect.

## Legal Principles

- A subsequent injury is compensable when it is proximately caused by disability resulting from an initial compensable work injury.
- Contributory negligence by an employee does not bar workers’ compensation benefits.
- Only willful misconduct—conduct beyond ordinary negligence, reflecting a level of culpability sufficient to constitute a superseding intervening cause—can sever causation between the initial compensable injury and a later injury.
- In assessing whether claimant conduct breaks the causal chain, courts consider the context, including medical restrictions and employer actions allowing return to similar work without warnings or limitations.

## Conclusion

The court upheld workers’ compensation benefits for a later, off-duty injury because the claimant established it flowed from dizziness caused by the earlier compensable accident, and the claimant’s conduct, even if imprudent, did not amount to willful misconduct that would cut off compensability.


Williams Constr. Co. v. Garrison, 400 A.2d 22 (Md. Ct. Spec. App. 1979)