COURT OF APPEALS SUMMARY - Williams vs. Delta Air Lines, Inc. and ACE USA

JENNIFER WILLIAMS, Employee/Appellant, v. DELTA AIR LINES, INC. and ACE USA, admin’d by SEDGWICK CLAIMS MGMT. SERVS., INC., Employer-Insurer/Respondents, et al.

WORKERS’ COMPENSATION COURT OF APPEALS – SEPTEMBER 22, 2025
No. WC25-6597

The employee was employed as a flight attendant for Delta Air Lines and was required to wear a mandatory employer-provided uniform. After the employer introduced a new “Passport Plum” uniform, the employee began experiencing skin rashes, hives, and other symptoms that intensified when she wore, or was in close proximity to, the uniform and subsided when she removed it. On November 12, 2019, the employee reported a work-related injury after experiencing significant skin reactions following multiple work shifts wearing the uniform. She later claimed a second work injury on January 29, 2020, alleging breathing difficulties when seated near coworkers wearing the same uniform.

The employee sought workers’ compensation benefits for occupational injuries arising from exposure to the employer-supplied uniform. The employer and insurer denied the claims, asserting that the employee failed to meet her burden of proof as to causation.

Following a hearing, the compensation judge denied both claims, relying primarily on the opinion of an independent medical examiner who concluded there was no objective evidence connecting the employee’s symptoms to the uniform. The compensation judge also found the employee’s testimony regarding causation not credible.

The employee appealed.

The Workers’ Compensation Court of Appeals reversed in part, vacated in part, and remanded. The WCCA concluded that the compensation judge erred by relying on an expert medical opinion that lacked proper foundation, where the expert failed to review a medical chart note documenting an objective skin reaction observed by a treating provider and relied on facts contrary to those found by the compensation judge. The WCCA held that the employee met her burden of proof for a compensable occupational injury occurring on November 12, 2019, and reversed and remanded for a determination of benefits for that injury.

With respect to the claimed January 29, 2020, injury involving breathing difficulties, the WCCA vacated the denial of the claim and remanded for reconsideration under the correct legal standard, concluding that while some evidence supported the claim, the record lacked clear medical opinions directly addressing causation.

 Summary prepared by Attorney Tristan Peters