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Nightmare about spiders caused him to fall, break foot: Does he get workers’ comp?

This firefighter/EMT was at the firehouse when he suffered an injury. Despite that, his employer says his injury wasn’t work-related. How did a court rule? 

Shawn Hansen worked as a firefighter and emergency medical technician for the City of Siloam Springs, AR. He worked 24-hour shifts and was required to stay on premises unless he was performing a work-related errand. The City provided him with sleeping accommodations and encouraged sleep during the night – he wasn’t expected to stay awake for the whole 24-hour shift.

On Nov. 5, 2015, Hansen was sleeping at the firehouse when he awoke from a bad dream at about 2:00 in the morning. Hansen said he had dreamed spiders were crawling on him. He jumped from his bed and fractured a bone in his left foot which eventually required surgery.

Hansen filed for benefits, but was denied. An administrative law judge found his injury wasn’t work-related. While sleeping at the firehouse benefited his employer, the dream about spiders and resulting injury was idiopathic (it happened spontaneously from an unknown cause), according to the ALJ. The Arkansas Workers’ Compensation Commission agreed with the ALJ’s decision. Hansen took his argument for benefits to a state appeals court.

Before the appeals court, Hansen argued his injury was due to his employer-provided sleeping arrangements. The court rejected that argument.

Hansen also claimed even if his injury was idiopathic, his work conditions contributed to his risk of injury. The appeals court said while employment conditions can contribute to the risk or aggravate an injury, there was no added danger from Hansen’s firehouse sleeping quarters than if he’d been sleeping in his own bed.

The appeals court agreed with the ALJ and Commission and denied Hansen’s request for workers’ comp benefits. Even though he was at the firehouse when he broke his foot, Hansen failed to prove he suffered a compensable injury.

(Shawn Seth Hansen v. City of Siloam Springs, Arkansas Court of Appeals, No. CV-17-562, 1/31/18)

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