Birnie v. Electric Boat Corp., 288 Conn. 392

Summary

The Connecticut Supreme Court considered whether a prior federal Longshore and Harbor Workers' Compensation Act proceeding precluded relitigation of causation in a state workers' compensation action under collateral estoppel. The court explained that Connecticut's substantial-factor standard generally requires employment to contribute to an injury in more than a de minimis way, but held that collateral estoppel was improper because the federal administrative law judge's decision did not clearly articulate the scope of the contributing-factor standard applied. The court reversed the decision of the compensation review board.

Holdings

1. Collateral estoppel was improperly applied because the federal administrative law judge's decision did not clearly articulate the scope of the contributing-factor causation standard, preventing an adequate comparison with Connecticut's substantial-factor standard.
2. Under Connecticut's Workers' Compensation Act, employment is a substantial factor in causing an injury when it contributes to the injury in more than a de minimis way; employment need not be the major, primary, sole, or predominant cause.

Questions Presented

1. Whether the causation standard applied by the federal administrative law judge under the Longshore and Harbor Workers' Compensation Act was sufficiently comparable to Connecticut's substantial-factor standard to support collateral estoppel in the subsequent state workers' compensation proceeding.
2. Whether the commissioner and compensation review board improperly barred Electric Boat from relitigating causation when the federal decision did not clearly define the scope of the contributing-factor standard applied.

Disposition

reversed_and_remanded