DC Court of Appeals Rules Injured Worker's Resignation Was Not Voluntary, Restoring Workers' Comp Benefits

Caroline McCall worked as a Clinical Systems Coordinator at a DC-area hospital for more than two decades. Over time her role expanded to cover inventory management, IT systems, and a range of administrative functions that required intensive, repetitive hand use. She developed bilateral carpal tunnel syndrome, a condition her treating physicians tied directly to the demands of her job.

McCall underwent two surgeries and received medical orders for specific workplace accommodations. Her employer did not fully implement those accommodations. Her pain continued to worsen. In December 2020, after years of deterioration and mounting physical and mental exhaustion, she resigned. She then filed for temporary total disability benefits under the DC Workers' Compensation Act.

An Administrative Law Judge found McCall's account credible, concluded that her carpal tunnel syndrome was work-related, and determined she could no longer perform her job as it existed at the time she left. The judge awarded temporary total disability benefits. The Compensation Review Board affirmed, applying the same legal standard and finding the factual record adequate to support the award.

The employer challenged both rulings before the DC Court of Appeals, arguing that the wrong time frame was used to evaluate McCall's capacity, that the evidentiary record was insufficient, and that the ALJ had not properly addressed whether McCall had voluntarily stepped away from work for reasons unrelated to her injury. The court rejected each argument in a published opinion issued February 26, 2026.

Attorneys Krista DeSmyter and Kevin H. Stillman of ChasenBoscolo Injury Lawyers represented McCall as counsel of record on the appeal, briefing the case for her before the Court of Appeals. The court's decision confirmed that the relevant question is whether a worker could perform her actual duties at the time she separated from employment, and that an injury-driven departure cannot be recharacterized as a voluntary income limitation.