Murray v. Utah Labor Commission
2013 UT 38
| Utah | 2013Background
- Murray sought workers’ compensation benefits for a July 13, 2008, on-the-job back injury as a park ranger at Red Fleet State Park.
- He was bending over the edge of a boat 35–40 degrees to untie the stern when a 5–6 inch wake rocked the boat.
- To steady himself, Murray shifted his weight, grabbed the boat, and twisted, then felt lower-back pain that worsened over hours and days.
- Medical treatment followed after Murray left work early due to increasing pain; a September 29, 2008 claim was denied.
- The ALJ found the injury aggravated a preexisting back condition but not caused by an unusual exertion, and the Commission affirmed.
- The Utah Court of Appeals reviewed the decision under an abuse-of-discretion standard and upheld the denial; certiorari was granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review for agency action applying law to facts | Murray: standard is traditional mixed question review, not abuse of discretion. | Labor Commission: standard is abuse of discretion under UAPA when agency interprets law. | Traditional mixed-question review applies; abuse-of-discretion standard not required. |
| Whether Murray established legal cause for the injury | Murray: employment contributed to injury given preexisting condition and unusual exertion. | Labor Commission: no unusual or substantial exertion; preexisting condition explains injury. | Murray failed to prove legal cause; court upholds denial of benefits. |
Key Cases Cited
- Drake v. Indus. Comm’n, 939 P.2d 177 (Utah 1997) (mixed questions; deference in applying law to facts; special errand rule discussion)
- Salt Lake City Corp. v. Labor Commission, 2007 UT 4 (Utah) (conditional deference for going-and-coming rule)
- Morton Int’l, Inc. v. Tax Comm’n, 814 P.2d 581 (Utah 1991) (statutory interpretation; incorporation of review standards)
- Allen v. Indus. Comm’n, 729 P.2d 15 (Utah 1986) (two-part test for legal causation requiring unusual exertion)
- Price River Coal Co. v. Indus. Comm’n, 731 P.2d 1079 (Utah 1986) (unusual exertion framework for employment injury cases)
- Miera v. Indus. Comm’n, 728 P.2d 1023 (Utah 1986) (recognizes unusualness in employment-related activities)