In the practice of workers’ compensation law, some of the most difficult claims to evaluate are those dealing with injuries sustained as a result of idiopathic conditions or conditions that arise spontaneously for which the specific cause is unknown. In the context of trucking, this situation usually arises when a driver suffers a heart attack, seizure, or an unexplained fall. While determining whether the injuries sustained are the result of an idiopathic condition, or if the condition itself is compensable, a case-by-case analysis is necessary; however, there are some general principles to consider.
In Cole v. Guilford County, 259 N.C. 724, 131 S.E.2d 309 (963), Plaintiff fell when her leg gave way as a result of a physical infirmity, the nature of which was unknown while serving on a jury. In determining that the fall was not compensable, the Court cited the well-established principle in discussing an injury caused by an idiopathic condition,
“The better-considered decisions adhere to the rule that where the accident and resultant injury arise out of both the idiopathic condition of the workman and hazards incident to the employment, the employer is liable. But not so where the idiopathic condition is the sole cause of the injury.”
In Dye v. Shippers Freight Lines, 118 N.C. App. 280, 454 S.E.2d 845 (1995), Plaintiff was a Truck Driver who suffered a heart attack while driving his usual route. Plaintiff filed a workers’ compensation claim arguing that the heart attack was brought on by long working hours, a rough ride caused by a nearly empty truck, equipment failure causing the temperature in his truck to be extremely high and prior stress related to his job conditions. In determining that the claim was not compensable, the Court found that Plaintiff had worked the long hours for which he complained of for over six months, that Plaintiff was driving a shorter route than usual at the time of the heart attack and that Plaintiff was generally accustomed to his work hours and work conditions.
In Vause v Vause Farm Equip. Co., 233 N.C. 88, 63 S.E.2d 173 (1951), Plaintiff was a driver who had a history of traumatic epilepsy. While driving, Plaintiff felt like he was going to have a seizure, so he pulled his truck over and laid down. Plaintiff then experienced a seizure, fell from his position and suffered a fractured and dislocated hip and a fractured pelvis. The Commission determined that the claim was compensable as Plaintiff was required to drive his truck to perform his work which subjected him to a particular hazard. The Court reversed the Commission and concluded that the claim was not compensable. The Court stated, “…the evidence here discloses no causal connection between the operating of the truck and the injury.” The Court further stated,
“We perceive in this evidence no showing that any hazard of the employment contributed in any degree to the unfortunate occurrence. The evidence affirmatively shows that it was solely the force of his unfortunate seizure that moved him from his position of safety to his injury. The cause of the fall is not in doubt. It is not subject to dual inferences. All of the evidence shows that the cause of the plaintiff’s fall was independent of, unrelated to and apart from the employment.”
As can be seen in the above-referenced cases, simply because an employee suffered an injury or medical condition that at first glance appears to be unrelated to his employment, there is no guarantee that the Commission or a Court will not eventually deem the injury or condition compensable. In fact, the Commission and Courts will take an in-depth look at the circumstances surrounding the injury or medical condition to determine if the hazards of the employment contributed in any way to said injury or medical condition.
The information published in Hedrick Gardner Alerts is general in nature and not intended to take the place of legal advice on any particular matter. © 2018 Hedrick Gardner Kincheloe & Garofalo LLP