On April 5, 2015, the Court of Appeals of Virginia issued a published decision concerning the proper legal standard when determining whether a Claimant's disregard of medical restrictions will bar a compensable injury. In Staton v. The Brothers Signal Co., et al., the Court clarified that "medical restrictions must be clearly communicated and specific before a claimant's violation of such restriction may bar the recovery of benefits. Generalized medical admonitions are insufficient... [b]y the same token, when a medical restriction has been communicated to an employee, the evidence must clearly demonstrate that the violation of the specific restrictions caused the employee's injury."
In Staton, the Claimant had been advised by a medical provider to avoid walking on uneven ground some fifteen to twenty years prior to the work accident. In the meantime, the Claimant had undergone subsequent treatment, including knee surgeries, and had been released to work without restrictions by other providers. He sustained a new knee injury when he stepped on soft ground that gave away. The Court overturned the Commission and determined that based on the facts presented, the work restrictions in question were insufficient to justify a preclusion of benefits. The full opinion can be found here.