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Case Profile
| Case Number | 2023-062819 |
| Board Office / Location | Atlanta |
| SBWC Publish Date | January 27, 2026 |
| ALJ | Viola S. Drew |
| ALJ Decision Date | December 12, 2025 |
| Appellate Panel | Not applicable |
| Appellate Decision Date | Not applicable |
| Suggested Injury | head; shoulder; back; knees; rib |
| Associated Decisions | No associated decisions were identified. |
Headnote
Claimant Found to be Employee; Award of TTD Benefits and Medical Treatment
Summary
The ALJ held a hearing on October 15, 2025, to determine the claimant’s entitlement to workers’ compensation benefits following an injury sustained on June 21, 2023, while working for the employer. The claimant sought TTD benefits, medical treatment, and attorney’s fees, asserting she was an employee, while the employer contended she was an independent contractor. The ALJ found that the claimant was indeed an employee, as the employer exercised significant control over her work conditions. The ALJ awarded TTD benefits retroactive to the date of the injury, mandated the employer to cover medical expenses, and assessed attorney’s fees against the employer for unreasonable defense actions.
Analysis
Issue:
Whether the claimant was an employee or an independent contractor.
Rule:
O.C.G.A. § 34-9-2(e) outlines the criteria for determining independent contractor status.
Analysis:
The ALJ analyzed the control exercised by the employer over the claimant’s work, including scheduling, work methods, and supervision. The claimant had no contract indicating independent contractor status and was paid hourly, which did not meet the criteria for independent contractor classification.
Conclusion:
The ALJ concluded that the claimant was an employee, not an independent contractor.
Issue:
Entitlement to TTD benefits and medical treatment.
Rule:
O.C.G.A. § 34-9-261 entitles employees to TTD benefits if they are unable to work due to a work-related injury.
Analysis:
The ALJ found that the claimant sustained significant injuries from the work-related accident and had been unable to return to work. The employer’s failure to provide necessary medical treatment contributed to the claimant’s ongoing disability.
Conclusion:
The ALJ awarded TTD benefits and mandated the employer to cover medical expenses.
Issue:
Assessment of attorney’s fees against the employer.
Rule:
O.C.G.A. § 34-9-108 allows for attorney’s fees to be assessed against a party if their defense is found to be unreasonable.
Analysis:
The ALJ determined that the employer’s defense regarding the claimant’s independent contractor status and the assertion of limited disability were unreasonable given the evidence presented.
Conclusion:
The ALJ assessed $20,000 in attorney’s fees against the employer.
Citations
Statutes
O.C.G.A. § 34-9-2(e)
(criteria for independent contractor)
O.C.G.A. § 34-9-261
(TTD benefits)
O.C.G.A. § 34-9-200
(medical treatment)
Cases
Golosh v. Cherokee Cab Co.,
226 Ga. 636
(1970) (employee vs. independent contractor)
Ratliff v. Liberty Mutual Ins. Co.,
149 Ga. App. 211
(1979) (doubt resolved in favor of employment)
Travelers Ins. Co. v. Moates,
102 Ga. App. 778
(1960) (doubt resolved in favor of employment)
Grier v. Proctor,
195 Ga. App. 116
(1990) (discretionary attorney fees)
Printpack, Inc. v. Crocker,
260 Ga. App. 67
(2003) (unreasonable grounds for attorney fees)
Mt. Vernon Mills, Inc. v. Gunn,
197 Ga. App. 109
(1990) (unreasonable grounds for attorney fees)
Topics
Code
050.10:
Employee status
Code
110.10:
TTD — entitlement / disability proof
Code
310.20:
Assessed fees — unreasonable defense
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