May 4, 2004
COURT RULES IN PRISON HIV
CASE EXPOSURE RISKS FOR SOME OFFICERS
DEEMED OCCUPATIONAL
By Lynne Tuohy, Courant Staff
Writer
The state Supreme Court Monday ruled
that human immunodeficiency virus - HIV
- is an occupational disease for prison
guards who serve on the department's
emergency response unit, but did not
extend that benefit to line officers
who routinely break up fights and risk
exposure to the virus through contact
with infected inmates.
Chief Justice William
J. Sullivan, who joined the 5-2 majority,
wrote a separate opinion in which he stated
that no distinction should be made between
emergency response unit members and those
guards regularly assigned to the housing
units.
"The fact that the risk was increased
for special response unit members does
not mean, however, that the risk was
not sufficiently high to constitute an
occupational disease for correction officers
who were not part of the special response
unit," Sullivan wrote.
The ruling
means the widow and two children of deceased
prison guard "John Doe" can
renew their efforts to secure worker's
compensation benefits. John Doe was hired
as a correction officer in 1986, and
volunteered for the specially trained
emergency response unit a year later.
While
working at the Bridgeport Correctional
Institution he frequently broke up fights,
including several that exposed him to
a significant amount of blood. He also
responded to a medical emergency in which
he had to put pressure on an inmate's
open wound, and received a puncture wound
during a cell shakedown, when his hand
struck a razor blade.
He left the department
in 1991, was diagnosed as HIV-positive
the following year and died in March
1993. His twins were 5 years old at the
time. The worker's compensation commission
first barred his widow's claim, saying
it was filed more than a year after her
husband's last day of work. She then
claimed his death was the result of an
occupational disease, and therefore fell
within the three-year window for filing
claims. The commission denied that claim,
and the widow appealed.
The court's majority
cited testimony that the HIV infection
rate in the prison population is 1 in
20, in contrast to an incidence rate
of 1 in 1,500 in the non-prison population.
"Breaking
up altercations and riots in an inmate
population with an HIV infection rate
of 1 in 20, or more than 70 times greater
than the infection rate of the non-incarcerated
population, is peculiar to the
decedent's occupation as a correction
officer in the emergency response unit," Justice
Flemming L. Norcott Jr. wrote.
"The
correction officer's duties of employment,
however, distinctly require intimate
physical contact with the inmates, often
in situations where blood and other bodily
fluids that transmit HIV are present,"
Norcott wrote. "This distinction
is enhanced in the present case due to
the decedent's involvement with the special
response unit."
Justices Christine
S. Vertefeuille and Peter T. Zarella
dissented, saying there was no evidence
that correction officers are at increased
risk of contracting HIV.
"I believe that the majority unduly
discounts the highly probative fact that
the only work-related HIV infection in
the correction department involved a
health care provider infected by a needle
stick," Vertefeuille wrote.
The minority
also noted that the infection rate from "splash incidents" -
in which blood or other bodily fluid
comes in contact with the skin or mucous
membranes of another - is 0.09, in contrast
to 0.3 for needle stick incidents. "The
risk of HIV exposure from a splash incident
is so minimal, fortunately, that it is
not an increased hazard of employment," Vertefeuille
noted.
Attorney Joel Faxon, who represents
John Doe's family, stressed that the
guard's period of employment and exposure
preceded the department's implementation
of precautionary measures, such as the
use of gloves.
"He had absolutely no other high-risk
behavior," Faxon said. "He
was in this environment on a daily basis.
It's just a very dangerous place to be.
Every couple of minutes you're walking
past a person who could be a carrier
and infect you."
The court's ruling revives the benefits
claim but does not necessarily mean the
family will prevail. Norcott stressed
the guard's family still must establish
that the HIV infection "actually
was caused by his employment as a correction
officer in that unit, and not another
source." Faxon
was undaunted, saying it's just "a
process of elimination."
Jon Pepe,
a correction officer and president of
the Connecticut State Prison Employees
Union/AFSCME Local 391, said there was
no justification for the court's distinguishing
emergency response unit members from
the line officers.
"As part of our duties, we are
all considered emergency responders if
a fight goes down," Pepe said. "We
don't call the emergency response unit.
We call a code and the correction officers
within the facility break up the fight
and get exposed to the blood. ...We're
all on the emergency response team by
our job descriptions."
Pepe said
about 200 officers, out of 4,000 statewide,
are designated as emergency responders
in the event a major disturbance or fire
breaks out. He also said that every officer
on a daily basis is assigned a post and
is given emergency response instructions
specific to that post and that day.
Union
officials will meet, Pepe said, and plan
a course of action in response to the
ruling. They likely will seek regulations
that expand the ruling to all officers,
he said. "Hopefully
the state of Connecticut will recognize
that this applies to all correction officers."
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2004, Hartford Courant