When Are Idiopathic Injuries Compensable?June 20, 2017 – Legal Alerts
One of the more complicated categories of workers’ compensation claims in Ohio involves “idiopathic” injuries. An Idiopathic injury is generally described as one which arose from circumstances peculiar to an individual employee, rather than one caused by a risk related to the employment. A common example of such an injury involves an employee who experiences an epileptic or diabetic seizure while at work. Since the seizure is the result of a personal medical condition particular to the individual employee, the injuries caused by the seizure itself would not be compensable.
Even when the cause of an injury is idiopathic, however, an injury can nevertheless be compensable if the employment significantly contributes to the injury by placing the employee in a position which increases the dangerous effects of the idiopathic incident. This fact makes the determination of such claims very fact-specific. For example, if an employee falls as the result of a non-work related seizure, the claim could be compensable if the employee strikes a machine while falling but would not be compensable if the employee simply falls to the ground, even while working on a hard surface such as concrete.
An interesting recent case decided by Ohio’s Eighth District Court of Appeals, Miller v. Horizon’s Health Services, involved a determination about whether an idiopathic incident occurring while an employee is driving for work should be compensable. In Miller, the employee lost consciousness while driving for work, apparently due to issues relating to her blood sugar or blood pressure. After losing consciousness at a stop light, the employee’s vehicle struck a light pole, resulting in a broken leg.
In Miller, the employee argued her injury was compensable, suggesting the light pole her vehicle struck was similar to a fall into a machine at a manufacturing facility. However, the Court of Appeals disagreed finding the roadway and light pole were not an added risk or hazard related to Miller’s employment. Instead, the court reasoned, Miller’s vehicle simply struck a common obstacle along the roadway where she was driving for work.
Because the determination of such claims can be so fact-specific, employers should carefully investigate any injury involving an unexplained fall or appearing to have been caused by a medical condition personal to the employee.