Connelly v. Hunt Furniture Co.
240 N.Y. 83 (1925)

Facts:

  • Claimant’s son, Harry Connelly, was employed by an undertaker as an embalmer’s helper.
  • He handled a corpse, which by reason of the amputation of a leg had become greatly decayed and was full of gangrenous matter.
  • Some of this matter entered a little cut in his hand, and later spread to his neck when he scratched a pimple with the infected finger.
  • General blood poisoning set in, and caused his death.

History:

  • His dependent mother obtained an award for death benefits.
  • The Appellate Division reversed, and dismissed the claim.

Issue:
Whether an infectious disease is an “accidental injury?”

Holding:
Yes. Case reversed.

Reasoning:
We think the injection of the poison was itself an accidental injury within the meaning of the statute. More than this, the contact had its occasion in the performance of the servant’s duties. There was thus not merely an accident, but one due to the employment. We attempt no scientifically exact discrimination between accident and disease or between disease and injury.”

Rule: An infectious disease contracted during employment is an “accidental injury,” thus warranting workers’ comp benefits.

Note: This case was one of the first points of breakthrough in the disease field.