In October 2015, Quinlan filed a claim with the Workers' Compensation Commission asserting that he developed meniscal tears in his right knee due to his job duties as a paramedic/firefighter for Baltimore County. After a hearing on Quinlan's claim, the Commission disallowed the claim, finding that he had not sustained an occupational disease arising out of and in the course of his employment.
Quinlan petitioned for judicial review in the Circuit Court. Before trial, the County moved for summary judgment, arguing that Quinlan failed to present evidence that his knee injury was an occupational disease or that it was related to the nature of his employment as a paramedic, but the motion was denied due to dispute of material facts. At trial, Quinlan and the County presented conflicting medical evidence. Quinlan's expert testified that there was literature to suggest that firefighters and/or EMT positions had higher rates of both meniscus tears and of arthritis, as opposed to persons performing less physically demanding jobs. The County's expert opined that Quinlan's other risk factors, such as his weight and age, were the primary cause of Quinlan's degenerative knee tears and not his occupation.
The jury returned a verdict in favor of Quinlan, that he had sustained an occupational disease of right knee degenerative tears arising out of and in the course of his employment. The Court of Special Appeals affirmed, and the Court of Appeals granted the County's petition for writ of certiorari.
As observed by the Court of Appeals, the parties' principal disagreement centered around whether degenerative meniscal tears were both (a) "caused" by Quinlan's occupation as a paramedic and (b) "due to the nature of an employment in which hazards of the occupational disease exist" [LE § 9-502(d)]. However, the crux of the case was the degree to which and how the occupational injury/disease must be due to the nature of an employment in which hazards of the occupational disease exist.
The County believed that Quinlan's condition was an ordinary disease of life and not due to the nature of an employment in which hazards of the occupational disease exist. The Court was not persuaded by that argument. According to the Court, the record before it clearly contained evidence that the nature of the job of a paramedic/firefighter places a person at greater risk for degenerative knee conditions, that Quinlan's job required him to engage in activities that account for the increased risk, and that he performed those activities for over 24 years. There was also evidence that his employment actually caused his degenerative tears. Therefore, the record contained sufficient evidence for the jury to reasonably conclude that Quinlan's knee tears were due to the nature of an employment in which hazards of the occupational disease exist.
A dissenting opinion raised concerns that the majority was broadly expanding workers' compensation coverage into coverage of common diseases of aging or lifestyle, potentially opening employers and insurers to potentially bear the full cost of a worker's pre-existing or underlying condition due to an aggravation of that condition caused in any degree and manner by the occupation. The dissent also raised concerns of occupational disease claims by those with underlying arthritic conditions in physically demanding jobs.
A copy of the Opinion can be found at: https://mdcourts.gov/data/opinions/coa/2019/50a18.pdf