Philbeck v. University of Michigan – Court Finds Work Injury Unexplained, Not Idiopathic

In order to obtain an award of workers’ compensation benefits in North Carolina, three elements must be proven:

  • That the injury was caused by an accident;
  • That the injury was sustained in the course of employment;
  • That the injury arose out of the employment.

In cases where the exact cause of the injury is not fully explained, employers will often seek to argue the injury was caused by idiopathic conditions. That is, that the worker suffered some medical condition unrelated to his or her employment that was the root cause of the accident and injury. gavel7.jpg

Charlotte workers compensation lawyers know that if the employer is successful in making a strong case for this, the injury will not be compensable.

This was the argument presented by the employer in the case of Philbeck v. University of Michigan, where a research worker suffered a fall while conducting work out-of-state.

The worker was 67-years-old at the time of the incident, and her job required her to travel from her home in North Carolina across the East Coast to interview individuals for social science research. On the day in question, she had traveled to Maryland and had stopped at an apartment complex to conduct interviews. After knocking on one door, the researcher learned the resident was not eligible to participate and she began walking back to her car. As she did, she fell and broke her left arm near the wrist.

She would later testify before the North Carolina Industrial Commission that she was unsure what caused her fall. She said seconds after she hit the ground, she remembered feeling dazed and disoriented. Doctors would later say she had lost consciousness for a short period. She looked down at her wrist and saw that it was “out of place” and “deformed.”

She sought medical treatment, and doctors at the emergency room were unable to determine the cause of the fall.

Later, her primary care physician reviewed the medical records from the hospital and hypothesized the patient fell due to heatstroke. However, there was no indication from the hospital records that the patient was overheated. Still doctor held firm in her position that the cause was most likely environmental, and that the patient had no underlying medical problems that might have predisposed her to a fall.

The patient had to undergo surgery and was later released to work with lifting restrictions. Several months later, the surgeon released her for work without restrictions, as she had reached maximum medical improvement.

When the researcher sought workers’ compensation benefits for the fall, her employer denied her claim, asserting that her injuries were the result of an idiopathic condition, as opposed to an unexplained fall. The latter would be compensable, while the former would not.

The doctrine of unexplained falls in workers’ compensation law holds that when the cause of a fall at work is unknown or unexplained and the commission makes no finding of force or condition independent of employment that may have caused it, the inference can be made that the fall arose out of the course of employment. The exception would be a fall caused by an idiopathic condition, which is one that arises from a mental or physical condition of the particular worker.

However, in order to prove this, employers have to show the injury is “clearly attributable” to the underlying condition. Here, the employer asserted the worker had fainted, and that the fall was not associated with any risk attributable to her work.

The commission said there was insufficient evidence to indicate the plaintiff fainted from heatstroke. While the patient herself indicated she may have been dehydrated, there was no medical evidence to support a finding that she fell due to dehydration.

It fell on the shoulders of the employer to prove the worker’s fall was due to some underlying medical condition unrelated to employment, and the employer failed to meet that burden of proof.

If you have been injured at work, contact the Lee Law Offices at 800-887-1965.

Additional Resources:
Philbeck v. University of Michigan, July 15, 2014, North Carolina Court of Appeals

More Blog Entries
Vicente Salas v. Sierra Chemical Co.: Workers’ Compensation and Undocumented Workers, July 8, 2014, Charlotte Workers’ Compensation Lawyer Blog

Contact Information