William F. Crawford v. W. Va. Dept. of Corrections

Background

Petitioner William F. Crawford, an inmate at the Charleston Work Release Center, was assigned to a road crew working for the West Virginia Division of Highways and was injured by a wood chipper while on that assignment.
Crawford had signed contracts (work-release placement and road-crew placement) that placed him under Corrections’ custody and allowed Corrections to reassign or terminate work assignments.
Corrections and DOH had a written agreement stating inmates performing services were not state employees and were not entitled to benefits including workers’ compensation; Corrections paid Crawford’s medical bills (~$90,000).
Crawford filed for workers’ compensation; the Claims Administrator, Office of Judges, and the Workers’ Compensation Board of Review denied benefits, relying on W. Va. Code § 23-4-1e(b).
Crawford appealed to the Supreme Court of Appeals of West Virginia arguing: (1) § 23-4-1e(b) does not bar coverage because work-release employment is voluntary; and (2) denial violates equal protection because privately employed inmates receive workers’ compensation while state-assigned inmates do not.
The Supreme Court affirmed the Board, holding § 23-4-1e(b) bars workers’ compensation for inmates performing work during confinement for a state agency and rejected Crawford’s equal protection challenge.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does W. Va. Code § 23-4-1e(b) bar workers’ compensation for an inmate injured while in a work-release program assigned to a state agency?	Crawford: statute excludes only work “imposed by administration”; work-release employment is voluntary, so statute doesn’t apply.	Corrections: although entry into program is voluntary, work is a condition of continued participation and thus is imposed by administration; statute bars benefits.	Court: § 23-4-1e(b) prohibits benefits for injuries sustained while performing work during confinement (including work-release assignments to a state agency).
Was Crawford an "employee" under workers’ compensation statutes, making § 23-4-1e(b) inapplicable?	Crawford: he qualifies as an employee under the statute.	Corrections: statutory exclusion applies notwithstanding employee status.	Court: did not decide employee status as § 23-4-1e(b) ("notwithstanding any provision to the contrary") bars benefits regardless.
Does denial of workers’ compensation to state-assigned work-release inmates violate Equal Protection because privately-employed inmates receive coverage?	Crawford: treating state-assigned inmates differently lacks rational basis; he would have received benefits if working for a private employer.	Corrections: inmates working for state agencies receive medical treatment paid by Corrections; private employers provide benefits; distinctions serve legitimate governmental/financial/competitive interests.	Court: No equal protection violation—both classes receive treatment for workplace injuries (source of payment differs), and record doesn’t show disadvantageous treatment.
Does denial amount to cruel and unusual punishment?	Crawford: denial is punitive and hinders reentry.	Corrections: issue inadequately briefed.	Court: Rejected as inadequately briefed; not considered.

Key Cases Cited

Johnson v. W. Va. Office of Ins. Comm’r, 226 W. Va. 650, 704 S.E.2d 650 (2010) (review of Board legal conclusions is de novo)
Chrystal R.M. v. Charlie A.L., 194 W. Va. 138, 459 S.E.2d 415 (1995) (statutory interpretation reviewed de novo)
Appalachian Power Co. v. State Tax Dep’t of West Virginia, 195 W. Va. 573, 466 S.E.2d 424 (1995) (plain statutory language controls interpretation)
Smith v. State Workmen’s Comp. Comm’r, 159 W. Va. 108, 219 S.E.2d 361 (1975) (primary object of statutory construction is legislative intent)
State ex rel. Gillespie v. Kendrick, 164 W. Va. 599, 265 S.E.2d 537 (1980) (work-release described as a privilege)
Craigo v. Legursky, 183 W. Va. 678, 398 S.E.2d 160 (1990) (inmate transferred to work release remains in custody of DOC)
Estelle v. Gamble, 429 U.S. 97 (1976) (governmental unit has obligation to provide medical care to inmates)
Nobles v. Duncil, 202 W. Va. 523, 505 S.E.2d 442 (1998) (reaffirming duty to provide inmate medical care)
State ex rel. Boan v. Richardson, 198 W. Va. 545, 482 S.E.2d 162 (1996) (equal protection analysis where differential treatment affected different benefit purposes)