Summary
The Utah Supreme Court clarified the causal standard for awarding workers’ compensation benefits for a subsequent non-workplace injury. It held that, under the direct-and-natural-results test, the original workplace injury must be a significant contributing cause of the subsequent injury, rather than merely a contributing cause. The court remanded the case to the Utah Labor Commission for application of that standard and reconsideration of whether a medical panel was required.
Topics
Practice areas
Questions Presented
- What causal connection must an employee establish between an initial workplace injury and a subsequent non-workplace injury to recover workers' compensation benefits for the subsequent injury?
- Whether the medical evidence required the Labor Commission to submit the issue of medical causation to a medical panel.
Holdings
- Under Utah's direct-and-natural-results test, an employee must establish that the initial workplace injury was a significant contributing cause of the subsequent non-workplace injury; a mere or minor causal contribution is insufficient.
- The court declined to decide whether the medical evidence required referral to a medical panel because the clarified causation standard required a new hearing.
Key quotations
“We hold that under the direct and natural results test, an employee must establish that the initial workplace injury was a significant contributing cause of the subsequent non-workplace injury, not merely a cause or a minor cause.” (¶ 37)
“We clarify that our causal standard under the direct and natural results test requires the employee to establish that the primary workplace injury was a significant contributing cause of the subsequent non-workplace injury in order to recover workers‘ compensation benefits for the subsequent injury.” (¶ 48)
Factual background
Steven H. Brown, a school bus driver, suffered a compensable lower-back injury in 2003 when he fell down bus steps and later underwent spinal surgery. After returning to work, he experienced continuing back problems and, in 2007, was knocked to the ground at a festival when a child jumped on his back, causing another disc herniation and additional surgeries. Medical experts agreed that the 2003 injury contributed to the 2007 condition, although one characterized the contribution as very minor.
Procedural history
An administrative law judge found that Steven H. Brown's 2007 non-workplace back injury was causally linked to his 2003 workplace injury and awarded workers' compensation benefits. The Labor Commission affirmed, and the Utah Court of Appeals affirmed the Commission. The Utah Supreme Court granted certiorari, clarified the governing causation standard, and remanded without deciding whether a medical panel was required.
Remand instructions
Remand to the Utah Labor Commission for a new hearing applying the significant-contributing-cause standard. The administrative law judge must also reconsider whether conflicting medical opinions require referral to a medical panel under the clarified standard.