Estate of Kyle Perkins by Megan Perkins v. North American Stainless

Summary

The Kentucky Supreme Court affirmed the dismissal of the Estate of Kyle Perkins’s workers’ compensation claim arising from his COVID-19 illness and death. The Court held that the Estate failed to prove by a preponderance of the evidence that Kyle’s illness arose out of or in the course of his employment or that his work increased his risk of contracting or aggravating COVID-19. The Court articulated a three-prong framework for communicable-disease claims but resolved the appeal at the threshold work-relatedness prong.