Andre Jones v. Crothall Laundry and New Hampshire Insurance Company, 69 Va. App. 767

On Oct. 14, 2017, Andre Jones (claimant) entered a fenced machinery area at Crothall Laundry through a small opening instead of the interlock gate and suffered a serious leg injury when moving machinery pinned him.
The interlock gate was designed to deactivate equipment when opened; claimant acknowledged knowing the rule requiring use of the gate and that it was enforced.
Video of the entry and accident was admitted; claimant testified he attempted to stop machines via an interior button/kick plate but did not succeed (these actions are not visible on video).
Coworker Nelson Gonzales testified he had seen others bypass the gate, sometimes in presence of supervisors, but never reported it; two managers testified the company enforced the gate rule and would terminate violators.
Deputy commissioner and then the Virginia Workers’ Compensation Commission found the claimant willfully breached a known safety rule, that the breach proximately caused the injury, and that the employer enforced the rule; benefits were denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether claimant's breach of the interlock-gate rule proximately caused the injury	Jones: proximate cause was his failure to stop the machines from inside (button/kick plate), not bypassing the gate	Employer: entering through the opening while machines ran (rather than using gate that deactivated them) directly led to injury	Court: affirmed — breach of gate rule proximately caused the injury
Whether employer enforced the known safety rule	Jones: employer tolerated violations (coworker saw bypasses, few reprimands), so defense fails	Employer: supervisors enforced rule; managers testified violations would be addressed/lead to termination	Court: affirmed — credible evidence established enforcement

Layne v. Crist Elec. Contractor, Inc., 64 Va. App. 342 (Va. Ct. App. 2015) (elements of willful breach defense and deference to Commission findings)
Mouhssine v. Crystal City Laundry, 62 Va. App. 65 (Va. Ct. App. 2013) (employer enforcement analysis; pattern-of-nondiscipline defeats defense when employer acquiesced)
Owens Brockway v. Easter, 20 Va. App. 268 (Va. Ct. App. 1995) (rule must be reasonable, known, for employee's benefit; breach must be intentional and proximate cause)
Office of the Comptroller v. Barker, 275 Va. 529 (Va. 2008) (definition of proximate cause)
Va. Elec. & Power Co. v. Kremposky, 227 Va. 265 (Va. 1984) (employer knowledge and acquiescence standard for defeating enforcement defense)