simplest application principle (Virginia) · Go Syfert
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simplest application principle in Virginia

11 Virginia opinions name it 1 courts 1997–2022 1 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
American Filtrona Co. v. Hanfordgreen
vactapp · 1993 · cited in 9 Virginia opinions naming this issue, 1997–2006
2 sentences

2006The doctrine of compensable consequences provides “when the primary injury is shown to have arisen out of and in the course of employment, every natural consequence that flows from the injury likewise arises out of the employment, unless it is the result of an independent intervening cause attributable to claimant’s own intentional conduct.” Bartholow Drywall Co., Inc. v. Hill, 12 Va. App. 790, 793-94 , 407 S.E.2d 1, 3 (1991) (quoting Morris v. Badger Powhatan/Figgie Int’l, Inc., 3 Va. App. 276, 283 , 348 S.E.2d 876, 879 (1986)). “‘The simplest application of this principle is the rule that al

2006The doctrine of compensable consequences provides “when the primary injury is shown to have arisen out of and in the course of employment, every natural consequence that flows from the injury likewise arises out of the employment, unless it is the result of an independent intervening cause attributable to claimant’s own intentional conduct.” Bartholow Drywall Co., Inc. v. Hill, 12 Va. App. 790, 793-94 , 407 S.E.2d 1, 3 (1991) (quoting Morris v. Badger Powhatan/Figgie Int’l, Inc., 3 Va. App. 276, 283 , 348 S.E.2d 876, 879 (1986)). “‘The simplest application of this principle is the rule that al

99
Bartholow Drywall Co., Inc. v. Hillgreen
vactapp · 1991 · cited in 3 Virginia opinions naming this issue, 1998–2006
2 sentences

2006The doctrine of compensable consequences provides “when the primary injury is shown to have arisen out of and in the course of employment, every natural consequence that flows from the injury likewise arises out of the employment, unless it is the result of an independent intervening cause attributable to claimant’s own intentional conduct.” Bartholow Drywall Co., Inc. v. Hill, 12 Va. App. 790, 793-94 , 407 S.E.2d 1, 3 (1991) (quoting Morris v. Badger Powhatan/Figgie Int’l, Inc., 3 Va. App. 276, 283 , 348 S.E.2d 876, 879 (1986)). “‘The simplest application of this principle is the rule that al

2006The doctrine of compensable consequences provides “when the primary injury is shown to have arisen out of and in the course of employment, every natural consequence that flows from the injury likewise arises out of the employment, unless it is the result of an independent intervening cause attributable to claimant’s own intentional conduct.” Bartholow Drywall Co., Inc. v. Hill, 12 Va. App. 790, 793-94 , 407 S.E.2d 1, 3 (1991) (quoting Morris v. Badger Powhatan/Figgie Int’l, Inc., 3 Va. App. 276, 283 , 348 S.E.2d 876, 879 (1986)). “‘The simplest application of this principle is the rule that al

23
Leonard v. Arnoldgreen
va · 1977 · cited in 2 Virginia opinions naming this issue, 1998–2022
2 sentences

1998This doctrine, also known as the chain of causation rule, provides that "'where the chain of causation from the original industrial injury to the condition for which compensation is sought is direct, and not interrupted by any intervening cause attributable to the [employee's] own intentional conduct, then the subsequent [condition] should be compensable.'" Food Distributors v. Estate of Ball, 24 Va. App. 692, 697 , 485 S.E.2d 155, 158 (1997) (quoting Leadbetter, Inc. v. Penkalski, 21 Va. App. 427, 432 , 464 S.E.2d 554, 556 (1995)) (other citation omitted). "'The simplest application of this p

1998This doctrine, also known as the chain of causation rule, provides that "'where the chain of causation from the original industrial injury to the condition for which compensation is sought is direct, and not interrupted by any intervening cause attributable to the [employee's] own intentional conduct, then the subsequent [condition] should be compensable.'" Food Distributors v. Estate of Ball, 24 Va. App. 692, 697 , 485 S.E.2d 155, 158 (1997) (quoting Leadbetter, Inc. v. Penkalski, 21 Va. App. 427, 432 , 464 S.E.2d 554, 556 (1995)) (other citation omitted). "'The simplest application of this p

22
Morris v. Badger Powhatan/Figgie International, Inc.green
vactapp · 1986 · cited in 1 Virginia opinions naming this issue, 2006–2006
2 sentences

2006The doctrine of compensable consequences provides “when the primary injury is shown to have arisen out of and in the course of employment, every natural consequence that flows from the injury likewise arises out of the employment, unless it is the result of an independent intervening cause attributable to claimant’s own intentional conduct.” Bartholow Drywall Co., Inc. v. Hill, 12 Va. App. 790, 793-94 , 407 S.E.2d 1, 3 (1991) (quoting Morris v. Badger Powhatan/Figgie Int’l, Inc., 3 Va. App. 276, 283 , 348 S.E.2d 876, 879 (1986)). “‘The simplest application of this principle is the rule that al

2006The doctrine of compensable consequences provides “when the primary injury is shown to have arisen out of and in the course of employment, every natural consequence that flows from the injury likewise arises out of the employment, unless it is the result of an independent intervening cause attributable to claimant’s own intentional conduct.” Bartholow Drywall Co., Inc. v. Hill, 12 Va. App. 790, 793-94 , 407 S.E.2d 1, 3 (1991) (quoting Morris v. Badger Powhatan/Figgie Int’l, Inc., 3 Va. App. 276, 283 , 348 S.E.2d 876, 879 (1986)). “‘The simplest application of this principle is the rule that al

11
Southern Iron Works, Inc. v. Wallacegreen
vactapp · 1993 · cited in 1 Virginia opinions naming this issue, 2001–2001
2 sentences

2001"A change of condition claim based on the aggravation of a prior compensable injury falls within this doctrine." Southern Iron - 6 - Works, Inc. v. Wallace, 16 Va. App. 131, 134 , 428 S.E.2d 32, 34 (1993) (citing Bartholow, 12 Va. App. at 797 , 407 S.E.2d at 5 ). "'The simplest application of this principle is the rule that all the medical consequences and sequelae that flow from the primary injury are compensable.'" American Filtrona Co. v. Hanford, 16 Va. App. 159, 163 , 428 S.E.2d 511, 513 (1993) (citation omitted).

2001"A change of condition claim based on the aggravation of a prior compensable injury falls within this doctrine." Southern Iron - 6 - Works, Inc. v. Wallace, 16 Va. App. 131, 134 , 428 S.E.2d 32, 34 (1993) (citing Bartholow, 12 Va. App. at 797 , 407 S.E.2d at 5 ). "'The simplest application of this principle is the rule that all the medical consequences and sequelae that flow from the primary injury are compensable.'" American Filtrona Co. v. Hanford, 16 Va. App. 159, 163 , 428 S.E.2d 511, 513 (1993) (citation omitted).

11
Food Distributors & Century Indemnity Co. v. Estate of Ballgreen
vactapp · 1997 · cited in 1 Virginia opinions naming this issue, 1998–1998
2 sentences

1998This doctrine, also known as the chain of causation rule, provides that "'where the chain of causation from the original industrial injury to the condition for which compensation is sought is direct, and not interrupted by any intervening cause attributable to the [employee's] own intentional conduct, then the subsequent [condition] should be compensable.'" Food Distributors v. Estate of Ball, 24 Va. App. 692, 697 , 485 S.E.2d 155, 158 (1997) (quoting Leadbetter, Inc. v. Penkalski, 21 Va. App. 427, 432 , 464 S.E.2d 554, 556 (1995)) (other citation omitted). "'The simplest application of this p

1998This doctrine, also known as the chain of causation rule, provides that "'where the chain of causation from the original industrial injury to the condition for which compensation is sought is direct, and not interrupted by any intervening cause attributable to the [employee's] own intentional conduct, then the subsequent [condition] should be compensable.'" Food Distributors v. Estate of Ball, 24 Va. App. 692, 697 , 485 S.E.2d 155, 158 (1997) (quoting Leadbetter, Inc. v. Penkalski, 21 Va. App. 427, 432 , 464 S.E.2d 554, 556 (1995)) (other citation omitted). "'The simplest application of this p

11
Leadbetter, Inc. v. Penkalskigreen
vactapp · 1995 · cited in 1 Virginia opinions naming this issue, 1998–1998
2 sentences

1998This doctrine, also known as the chain of causation rule, provides that "'where the chain of causation from the original industrial injury to the condition for which compensation is sought is direct, and not interrupted by any intervening cause attributable to the [employee's] own intentional conduct, then the subsequent [condition] should be compensable.'" Food Distributors v. Estate of Ball, 24 Va. App. 692, 697 , 485 S.E.2d 155, 158 (1997) (quoting Leadbetter, Inc. v. Penkalski, 21 Va. App. 427, 432 , 464 S.E.2d 554, 556 (1995)) (other citation omitted). "'The simplest application of this p

1998This doctrine, also known as the chain of causation rule, provides that "'where the chain of causation from the original industrial injury to the condition for which compensation is sought is direct, and not interrupted by any intervening cause attributable to the [employee's] own intentional conduct, then the subsequent [condition] should be compensable.'" Food Distributors v. Estate of Ball, 24 Va. App. 692, 697 , 485 S.E.2d 155, 158 (1997) (quoting Leadbetter, Inc. v. Penkalski, 21 Va. App. 427, 432 , 464 S.E.2d 554, 556 (1995)) (other citation omitted). "'The simplest application of this p

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Berglund Chevrolet, Inc. v. Landrum green
vactapp · 2004
2 sentences

2022Berglund Chevrolet, Inc. v. Landrum, 43 Va. App. 742, 750-54 , 754 n.5 (2004) (“The simplest application of this principle is the rule that all the medical consequences and sequelae that flow from the primary injury are compensable.” (quoting 1 Arthur Larson & Lex K.

2018“The simplest application of this principle is the rule that all the medical consequences and sequelae that flow from the primary injury are compensable.” Berglund, 43 Va. App. at 750 , 601 S.E.2d at 697 (quoting 1 Arthur Larson & Lex K.

22018–2022

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (8) VA § Va. Code Ann. § 65.2-601 (6) VA § Va. Code Ann. § 65.2-708 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

VA 11 (1997–2022) IL 2 (2018–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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