Quast v. Utah Labor Comm'n
2017 UT 40
| Utah | 2017Background
- In 2007 Rashell Quast slipped at work, aggravating a preexisting thoracic spine injury; after two surgeries she claimed permanent total disability (PTD) benefits under Utah law.
- Medical and functional evidence conflicted: some providers suggested total disability; Huntsman's consultant and functional capacity tests indicated restrictions to light work (no lifting over 20 lbs, avoid repetitive spinal flexion) and noted symptom magnification.
- Quast testified she could not perform basic tasks (lifting milk, standing/bending), has limited education and preexisting conditions; Huntsman produced vocational testimony identifying light, unskilled jobs in the area consistent with the medical restrictions.
- An ALJ awarded PTD benefits; the Labor Commission reversed, finding Quast failed to prove she was limited in her ability to do "basic work activities" and (separately) that the employer had not proven availability of other work.
- The Utah Court of Appeals reinstated the ALJ, holding any impairment that negatively affects typical workplace activities suffices to show a limit on basic work activities.
- The Utah Supreme Court granted certiorari, rejected the court of appeals' standard, held substantial evidence supported the Labor Commission's finding that Quast did not prove a limitation of basic work activities, and reversed the court of appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an impairment that merely "negatively affects" some workplace activities qualifies as a limit on "basic work activities" under the PTD statute | Quast: any impairment that negatively affects typical work activities establishes a limit on basic work activities | Labor Comm'n/Huntsman: limit must meaningfully impact ability to perform core tasks across a broad spectrum of jobs; mere negative effect is insufficient | The court held the limitation must meaningfully impact core tasks; mere negative effect does not meet the statutory "limit" requirement (affirming Labor Commission) |
| Whether substantial evidence supports the Labor Commission's finding that Quast was not limited in her basic work activities | Quast: her testimony and medical history show incapacity for basic work activities | Huntsman: medical, FCEs, and vocational testimony show ability to perform light, unskilled work; record shows symptom magnification and unreliable effort | Held: substantial evidence supports the Labor Commission's finding for Huntsman; a reasonable mind could credit medical and vocational evidence over Quast's testimony |
| Who bears the burden to prove that "other work [is] reasonably available" under the PTD statute | Quast: employer failed to prove other work was available (court of appeals adopted this view) | Huntsman: burden lies with Quast as the claimant to prove all elements of PTD including lack of other available work | Held: claimant (employee) bears the burden on all PTD elements; it was error to place burden on employer |
| Remedy after misallocation of burden on "other work reasonably available" | Quast: court of appeals awarded benefits because employer allegedly failed to prove availability | Labor Comm'n: found employer evidence deficient and therefore ruled for Quast on that element | Held: Supreme Court reversed court of appeals; remand not required on this point because Quast's failure on basic work activities was dispositive, but Labor Commission and court of appeals erred in placing burden on employer |
Key Cases Cited
- Oliver v. Utah Labor Comm'n, 424 P.3d 22 (Utah 2017) (interpreting the "basic work activities" limitation requirement)
- Nichols v. Jacobsen Constr. Co., 374 P.3d 3 (Utah 2016) (review standards on certiorari)
- Martinez v. Media-Paymaster Plus/Church of Jesus Christ of Latter-Day Saints, 164 P.3d 384 (Utah 2007) (substantial-evidence review and burden of proof principles)
- Provo City v. Utah Labor Comm'n, 345 P.3d 1242 (Utah 2015) (employee bears burden on all PTD elements)
- Quast v. Labor Comm'n, 362 P.3d 292 (Utah Ct. App. 2015) (court of appeals decision reversed here)