Supreme Court of Virginia

James D. Morris v. James W. Morris; Door Systems, Inc., and Erie Insurance Exchange v. Clyde M. Hood…

November 10, 1989238 Va. 578

Summary

The Court held that injuries caused by repetitive trauma, continuing mental or physical stress, or other cumulative events do not qualify as an "injury by accident" under the Workers’ Compensation Act. A compensable accidental injury requires proof of an identifiable incident or sudden precipitating event that produces an obvious sudden mechanical or structural change in the body. The Court rejected the Court of Appeals’ broader work-activity approach and reversed the awards in all three consolidated cases.