American Furniture Co. v. Doane – Case Brief Summary (Virginia)

In American Furniture Co. v. Doane, 230 Va. 39, 334 S.E.2d 548 (1985), the employee suffered a work-related injury to her back.

After the employee had surgery and recovered, the attending physician released Doane to return to light-duty work.

Doane, however, failed to report for light-duty work because of impairments to her hand, which were unrelated to and developed after her back injury.

Doane's treating physician opined that the injury resulting from the industrial accident did not preclude her from performing the offered selective employment.

The Supreme Court found the employer had met its burden of producing evidence that the selective employment offered to Doane was within her residual capacity.

The Court found that Doane, however, failed to show she was justified in refusing the selective employment. The Supreme Court ruled that Doane failed to show the necessary causal connection between her arm impairment and her compensable injury.

The Court held that "an employer, therefore, is absolved of liability for compensation if the employee refuses selective employment because of a physical condition unrelated to the original industrial accident and arising since the accident." Doane, 230 Va. at 43, 334 S.E.2d at 550.