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Sorrels v. Foreign Mission Board of the Southern Baptist Convention

Citations: 227 Va. 6; 313 S.E.2d 370; 1984 Va. LEXIS 260Docket: Record No. 821878

Court: Supreme Court of Virginia; March 9, 1984; Virginia; State Supreme Court

Narrative Opinion Summary

The case involves a claimant who appealed the Industrial Commission's dismissal of his workers' compensation claim. The claimant, having applied to serve as a volunteer in Nigeria under the Foreign Mission Board of the Southern Baptist Convention, sustained severe injuries while in Nigeria. The Commission dismissed the claim on the grounds that he was a 'volunteer' rather than an 'employee' under the Workers' Compensation Act, and that his services were performed exclusively outside Virginia, thereby placing them outside the jurisdiction of the Act. The claimant contended that no document explicitly stated his services would be outside Virginia, but the Commission found a mutual understanding existed to that effect. The court affirmed the Commission's ruling, concluding that the evidence supported the finding of exclusive foreign service, thus dismissing the claim for lack of jurisdiction. This decision underscores the significance of the employment status and the geographical scope of services in determining workers' compensation coverage under state law.

Legal Issues Addressed

Definition of Employee under Workers' Compensation Act

Application: The court determined that the claimant was a 'volunteer' rather than an 'employee,' affecting his eligibility for workers' compensation benefits.

Reasoning: Claimant Robert W. Sorrels appealed an order from the Industrial Commission regarding his workers’ compensation claim, which was dismissed on two grounds: he was deemed a 'volunteer' rather than an 'employee' under the Workers’ Compensation Act.

Interpretation of Employment Agreements

Application: The court found that despite the absence of an explicit document, the mutual understanding between the parties indicated that the claimant's work was exclusively in Nigeria.

Reasoning: The Commission found that the mutual understanding between Sorrels and the Board did indicate that his work was to be performed exclusively in Nigeria.

Jurisdiction of the Workers' Compensation Act

Application: The Commission ruled that it lacked jurisdiction as the claimant's services were to be performed exclusively outside Virginia, thus not covered by the state’s Workers' Compensation Act.

Reasoning: The Commission ruled there was no jurisdiction to hear it based on the understanding that his services were exclusively outside Virginia.