Quast v. Labor Commission
2015 UT App 267
| Utah Ct. App. | 2015Background
- In 2007 Quast slipped and fell at work, aggravating a preexisting back condition; she underwent spine surgeries in 2008 and 2010 and has not worked since shortly after the 2008 surgery.
- Quast filed for permanent total disability (PTD) compensation based on an impairment limiting her ability to perform basic work activities (lifting, bending, etc.).
- An ALJ initially awarded PTD; the Labor Commission vacated and remanded for additional medical evidence; after a second ALJ hearing PTD was again awarded.
- On review the Commission reversed, finding Quast’s thoracic-spine impairment limited lifting over 20 pounds and repetitive bending but concluding she was not limited in performing basic work activities because she retained a ‘‘reasonable’’ or ‘‘good functional’’ capacity.
- Quast petitioned for judicial review in the Utah Court of Appeals, arguing the Commission applied the wrong legal standard by requiring a ‘‘reasonable’’ limitation rather than any limitation on basic work activities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Quast has an impairment that "limits" ability to do basic work activities under Utah Code § 34A-2-413 | Quast: "Limit" requires only that the impairment place some limitation on basic work activities (e.g., lifting, bending) | Commission: Quast retains reasonable functional capacity; limitations are not sufficiently restrictive to establish a limited ability to perform basic work activities | Court: "Limit" requires only that the impairment negatively affect ability to perform basic work activities; Commission applied too stringent a "reasonable"-capacity standard and decision reversed |
| Whether Commission may consider claimant's overall "reasonable" functionality when assessing limitation of basic work activities | Quast: The statute and precedents require assessing whether impairments negatively affect basic work activities, not overall reasonable functionality | Commission: Proper to consider claimant’s remaining functional capacity and reasonableness of limitations | Court: Considering "reasonable" functionality is error; inquiry must focus on whether disability negatively affects basic work activities |
Key Cases Cited
- Provo City v. Labor Comm’n, 345 P.3d 1242 (Utah 2015) (explaining PTD requires proof that impairments limit ability to perform basic work activities across a broad spectrum of jobs)