In Ackley, the claimant challenged the Utah Labor Commission’s (the Labor Commission) denial of her claim for worker’s compensation benefits, contending that the Labor Commission mis-applied the idiopathic fall doctrine in her claim.
The claimant fell to a concrete floor while working at Lowe’s (respondent) after a ganglion cyst burst, causing such pain, that the claimant lost consciousness and fell to the ground, suffering multiple injuries as a result. The claimant filed a claim for benefits with the Labor Commission. The respondents did not deny that the claimant fell and was injured while at work but argued that the fall was caused by a pre-existing condition; and therefore, not compensable.
In its original review of the claim, the Utah Court of Appeals (the Court) remanded the claim to the Labor Commission, holding that the fall was idiopathic, as it originated from the claimant’s pre-existing condition. The Labor Commission was to determine if the working conditions contributed to the hazards of the fall and increased the risk of injury to make the injury compensable. The Labor Commission held that the claimant’s employment did not place her in a position that increased the dangerous effects of an idiopathic fall and denied her benefits.
The claimant again appealed the Labor Commission’s decision which led to this ruling by the Court. This time, the Court held that an aspect of the claimant’s workplace environment, such as the hardness of the floor in this claim, may qualify as an aggravating factor, as long as the claimant can meet their burden of proof and show that this aggravating factor increased the severity of the claimant’s injuries. The claim was again remanded to the Labor Commission.
Ackley v. Labor Comm'n & Lowe's, 2024 UT App. 119 (Utah Ct. App. 2024)
Want to know more? Contact Jakub Lewandowski at [email protected] or 877-259-5693.
