A Missouri appellate court has, once again, narrowly read the state’s workers’ compensation law to reduce the amounts that have to be paid by businesses after a workplace injury. In this case, the issue concerned idiopathic diseases, or those that do not have an identifiable cause.
Obese Worker Dies from Heatstroke
The case is Halsey v. Townsend Tree Service Co., and involves the tragic case of a 23-year old worker who, on his fourth day on the job, died of heatstroke after working 10-hour days outdoors. The heat index on the day he passed out was 114. He died the next day in the hospital from hyperthermia.
The Occupational Safety and Health Administration (OSHA) cited the landscaping company that employed the worker for safety violations.
Importantly for the subsequent legal claims, the worker weighed approximately 300 pounds.
Victim’s Parents Try Filing Wrongful Death Claim and Avoid Workers’ Compensation
Because the accident happened on the job, there was the strong possibility that Missouri’s workers’ compensation scheme would cover the death. However, the parents of the employee realized that the death or survivor benefits of a workers’ compensation award were far less than what they could recover in a personal injury lawsuit for wrongful death.
Therefore, in an unusual move, the parents aimed to show that workers’ compensation would not cover their son’s workplace death.
Idiopathic Conditions and Workplace Injuries
Under Missouri Statute 287.020.3(3), workers’ compensation law does not cover injuries “resulting directly or indirectly from idiopathic causes.”
An “idiopathic” condition is something that does not have a known origin and that is peculiar to the individual, like a sudden dizzy spell that had nothing to do with the working environment.
In an attempt to get out of the workers’ compensation system, the parents of the deceased worker in Halsey claimed that their son’s obesity was an idiopathic cause of his heatstroke.
Court Adopts “But For” Test for Idiopathic Causes
The Missouri Court of Appeals, though, insisted that workplace injuries caused by idiopathic conditions could only get outside of the workers’ compensation scheme if the idiopathic condition was the “but for” cause of the injury or death. In the court’s eyes, it is not enough for the idiopathic condition to contribute to the injury: Instead, the injury could not have occurred, but for the idiopathic condition.
Applying that to the case of fatal heatstroke, the court ruled that the worker’s obesity merely contributed to his death, in spite of the fact that obesity is a big risk factor for getting heatstroke. This meant that the worker’s death did not fall outside the realm of Missouri’s workers’ compensation law, which meant that the parents could not file the wrongful death claim that they believed would recover the compensation that they truly deserved, and instead pushed them into pursuing limited survivor benefits with a workers’ compensation claim.
Workers’ Compensation and Personal Injury Lawyers at the Smith Law Office
The workers’ compensation and personal injury lawyers at the Smith Law Office serve victims of workplace accidents in St. Joseph, Kansas City, Springfield, and the rest of western Missouri.
Contact them online or call their law office at (816) 875-9373 for legal help and representation.