Idiopathic falls – when are they compensable?

The Utah Court of Appeals has provided important clarification regarding the compensability of injuries from idiopathic falls in the workplace.

Its recent ruling in Ackley v. Labor Commission established that such falls can qualify for workers’ compensation if the employee can demonstrate that the workplace environment – in this specific case, the hardness of the floor – exacerbated the injury.

The case involved an employee who sustained multiple injuries after collapsing on to a level ground floor at work. The fall occurred after a hand cyst ruptured, causing intense pain and loss of consciousness. The Utah Court of Appeals found the fall to be idiopathic – stemming from the worker’s internal or personal condition – and sent the case back to the Utah Labor Commission.

At the time, the Court asked the Commission to evaluate whether the conditions of the workplace contributed to the severity of the injury and created additional risk, thus making the injury compensable under workers’ compensation law.

Upon review, the Labor Commission denied benefits, determining that there was insufficient evidence to conclude that the employment environment heightened the dangers of the fall. The employee then appealed further.

In response, the Court admitted a shortcoming before clarifying its decision.

“We take responsibility for previously returning this matter to the Commission with less than clear instructions on how to proceed,” reads part of the new ruling. “As discussed below, we now determine that compensation can be awarded in idiopathic fall cases like Ackley’s if an employee can demonstrate that the hardness of the workplace floor increased the severity of the injuries caused by an idiopathic fall.”

Explaining, the Court said: “When it concluded that idiopathic falls to level ground are generally not compensable in Utah and denied Ackley’s claim for benefits, the Commission was making a good-faith effort to interpret our previous opinion.”

In its earlier opinion, the Court stated that compensability for idiopathic workplace falls depends on whether a condition of employment increased the risk of injury. The Commission then recognized that most of the potential workplace hazards identified in the first opinion – including shelving and a machine – did not contribute to the injury because the employee did not hit anything other than the floor.

The Court stated in its latest judgment: “We agree with the Commission that a per se rule that requires the payment of benefits based simply on the possibility of an increased risk of injury from a fall to level ground at a workplace does not accurately describe the law in Utah.

“Instead, the potential workplace hazards must actually contribute to the injuries sustained. Stated another way, increased risk alone is not enough; the risk must actually result in increased or aggravated  injuries.”

That leaves the claimant, then, with the actual floor on which she fell.

“Even though Ackley did not hit any of the surrounding hazards on her way to the floor, she did strike her head on the concrete floor of her work area, an event that caused Ackley to suffer injuries,” the Court pointed out.

It went on to say: “Here, we clarify that, in appropriate cases, idiopathic falls to level ground on a hard floor might be compensable, but only if the employee can show, as a factual matter, that the hardness of the floor made the resulting injuries worse.”

The case is among those being monitored by the National Council on Compensation Insurance.

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