For the second time in a month, the South Carolina Supreme Court took on the issue of idiopathic injuries in the workplace. While the definition for the term “idiopathic” does include the word “unexplained,” that’s not exactly the way the court interprets it for purposes of granting workers’ compensation benefits.
It’s true that work injuries must arise out of and in the course of one’s employment. But when an injury – such as a fall – occurs at work, and there is no explanation for why, that does not mean the injuries are not compensable. What would render the injuries the result of an idiopathic incident would be if the cause was something personal to the injured; something that could have occurred anywhere.
Examples might be a heart attack, stroke, seizure or diabetic episode – things that could happen to the worker at any place and time, but just happened to have occurred at work. Even then, if some work-related condition exacerbated the incident or injury, the commission might still find the injury partially compensable.
What is not considered idiopathic by the court’s standard is an injury without clear explanation. Where there is little to no evidence presented the injury was precipitated by a condition personal to the worker, and yet there is no obvious work-related cause, benefits will still likely be granted to the worker.
That was the holding in the case of Nicholson v. SC Dept. of Social Services, which closely mirrors the decision earlier in the month of Barnes v. Charter 1 Realty.
According to court records in Nicholson, claimant was a supervisor working investigations for the state department of social services. As part of her job, she attended weekly meetings to review and update case files. One day, she was scheduled for a meeting on the lower floor, and began walking there with a stack of files in hand. In so doing, her shoe caught the carpet and she fell, suffering injuries to her neck, back and shoulder.
She later filed a Form 50, alleging compensable injuries and seeking payment for past medical treatment, additional medical treatment and temporary total disability for the month-and-a-half she was off work receiving this treatment. The agency and its insurer conceded claimant fell at work, but denied the injuries were compensable because, they argued, they did not arise out of her employment.
A single commissioner denied her benefits, finding there was nothing specific to the floor at the agency that contributed to her fall and thus, she could have fallen anywhere.
On appeal to the full commission, that finding was reversed, stating her injuries did not result from an idiopathic or unexplained fall because she had identified a specific, non-internal reason for it – that her shoe scuffed the carpet. Even though the files she was carrying were not a contributing factor, the full commission found it was irrelevant that she could have fallen anywhere and her injuries were thus compensable.
The case was then appealed to the court of appeals, which again reversed, finding that while the fall was not idiopathic or unexplained, there was no special condition or hazard particular to her employment that contributed to her injuries.
The South Carolina Supreme Court grant certiorari (review) and reversed the appellate court. It was noted negligence and usually fault do not affect the issue of whether a worker is entitled to benefits.
Our Spartanburg workers’ compensation lawyers know this is true even in cases where the employer’s conduct is “flawless in its perfection” and where the worker’s conduct is “abysmal in its clumsiness, rashness and ineptitude.” It does not matter. So long as it arose out of and in the course of one’s work, it’s compensable. The reverse is also true – where the employer’s conduct is careless and the worker’s conduct was stellar. The same benefits will be issued regardless.
Contact the Carolina injury lawyers at the Lee Law Offices by calling 800-887-1965.
Nicholson v. SC Dept. of Social Services, Jan. 14, 2015, South Carolina Suprem Court
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Schultz v. Workers’ Compensation Appeals Board – Coming and Going Rule Exception, Jan. 17, 2015, Spartanburg Workers’ Compensation Lawyer Blog