Barnes v. Charter 1 Realty – South Carolina Supreme Court Weighs Idiopathic Injury Claim

In a South Carolina workers’ compensation claim, it is not enough that the incident/injury/illness happened while claimant was at work. The law says it must arise out of and in the course of one carrying out work or work-related duties.
When injuries occur at work as the result of some spontaneous or obscure or unknown cause, this is referred to as an “idiopathic injury,” and it’s important for injured workers to understand because it could be the basis of a claim denial, if your company/insurer is successful in asserting it.

Recently, the South Carolina Supreme Court took on a purported case of idiopathic injury in a workers’ compensation claim in Barnes v. Charter 1 Realty.

The court was required to clarify the idiopathic exception to workers’ compensation claims. It involves a worker who tripped and fell at work while walking down the hall to check an e-mail for a colleague.

There was no evidence her fall was precipitated by some internal condition. She hadn’t fainted. Her legs didn’t give out. She didn’t suffer any other condition that might have caused her to fall. And yet, the single commissioner and then later the appellate panel ruled the fall was idiopathic and thus not compensable. Thankfully, the South Carolina Supreme Court disagreed, reversed and remanded.

According to court records, claimant stumbled while walking to a colleague’s office, and in so doing, sustained serious injuries. These included a left broken leg, left broken arm and rotator cuff.

In the workers’ compensation claim, she alleged she was hurrying because her co-worker had asked her to carry out this task by noon, and it was already 11:30 a.m. This, she said, caused her to fall.

There was evidence presented indicating her husband worried about the height of her heels and had also warned her to pickup her feet more when she walked.

Single commissioner ruled that because there was no deficiency in the carpet or other hazard that may have caused the fall and there was not other explanation, the fall was idiopathic and therefore not compensable. Further, commissioner noted claimant offered no evidence her employment contributed to her fall. Appellate panel affirmed.

In its review, justices with the state high court noted firstly, workers’ compensation law is supposed to be construed liberally in favor of the worker.

Here, the court found the lower courts’ holding departed from settled jurisprudence pertaining to idiopathic falls, which are the exception from the general rule that work-related injuries are compensable. The court noted an idiopathic fall would be one that is brought on by a purely personal condition that is totally unrelated to employment. For example, if a person falls as a result of suffering a heart attack or seizure, injuries incurred as a result of that fall might not be considered compensable unless some workplace condition contributed to the severity of that injury.

The general idea is an idiopathic injury stems from a condition particular to the worker and could have occurred anywhere – but just happened to occur at work.

In this case, just because the lower courts did not know what caused claimant’s fall does not mean they could deny the claim. Unexplained circumstances are not enough to prove an injury was idiopathic in South Carolina workers’ compensation law. Rather, there must be some indication the cause was internal.

That was not the case here.

Contact the Carolina injury lawyers at the Lee Law Offices by calling 800-887-1965.

Additional Resources:
Barnes v. Charter 1 Realty, Jan. 14, 2015, South Carolina Suprem Court

More Blog Entries
Schultz v. Workers’ Compensation Appeals Board – Coming and Going Rule Exception, Jan. 17, 2015, Rock Hill Workers’ Compensation Lawyer Blog

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