Karns v. Liquid Carbonic Corp.

Workmen’s compensation benefits are denied in Maryland where the injury resulted solely from the intoxication of the injured or solely from the effect of drugs.1 Self-inflicted injury or wilful misconduct are the other statutory grounds for disentitlement to benefits but the statute omits the word “solely” in both instances. Md. Code, Art. 101, § 45.

In this case, the Commission found that appellant’s injuries, sustained while driving his employer’s truck on June 30, 1972, were the result of wilful misconduct “due to alcoholic intoxication” and that he was not entitled to benefits. On appeal…