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Hewett v. CONSTRUCTOR'S SUPPLY CO., INC.

Citations: 224 S.E.2d 297; 29 N.C. App. 395; 1976 N.C. App. LEXIS 2489Docket: 7510IC865

Court: Court of Appeals of North Carolina; May 5, 1976; North Carolina; State Appellate Court

Narrative Opinion Summary

This case concerns a claimant's appeal against a decision by the North Carolina Industrial Commission regarding a workers' compensation claim. The claimant alleged an injury resulting from a fall at work, which was not initially reported during the hearing. After retaining new counsel, the claimant sought to introduce additional evidence post-hearing, asserting that he experienced pain from a fall not mentioned previously. The Commission, however, upheld the hearing officer's decision without addressing the claimant's motion for remand or the accompanying affidavit. On appeal, the claimant contended that the Commission's findings contradicted the evidence, as it concluded no accident occurred. The Court of Appeals affirmed the Commission's decision, ruling that there was no evidence of an accident when the claimant moved from a squatting to a standing position. The court's decision underscores the necessity for clear evidence of an accident in workers' compensation claims and illustrates procedural challenges in post-hearing submissions.

Legal Issues Addressed

Procedural Due Process in Workers' Compensation Claims

Application: The Commission's failure to consider the claimant's motion for remand and affidavit was not addressed, yet the decision was upheld, suggesting that procedural omissions did not affect the outcome.

Reasoning: On July 24, 1975, the Commission upheld the hearing officer's award without addressing Hewett's motion or affidavit.

Workers' Compensation and Definition of 'Accident'

Application: The court affirmed that an accident must be supported by evidence, and the claimant's injury did not qualify as it occurred during a routine movement without any unforeseen event.

Reasoning: The Court of Appeals affirmed the Commission's decision, agreeing that there was no evidence supporting that an accident occurred when Hewett transitioned from a squatting to a standing position.