
A West Virginia appellate court has ruled that Tyler Carroll, a worker who required a double leg amputation after being struck by a vehicle, is entitled to workers’ compensation benefits. The incident occurred in May 2021 when Mr. Carroll, a third-year union apprentice with the Plumbers and Pipefitters Local Union #625, was on his way from Pittsburgh to Charleston for a project at a federal courthouse. While en route, he and a colleague witnessed a vehicle accident and attempted to assist the victims. During this effort, Mr. Carroll was hit by another vehicle at the scene.
Initially, a claim administrator denied Mr. Carroll’s application for workers’ compensation, arguing that his injuries occurred due to a deviation from his employment duties. This decision was first overturned by a compensation judge but later reinstated by a review board. The appellate court, however, reversed the board’s determination, citing that Mr. Carroll’s co-worker’s actions provided "implicit authorization" for Mr. Carroll’s actions, thereby bringing his efforts within the scope of employment. This implicit authorization was deemed sufficient to make Mr. Carroll’s claim compensable.