SAPKO v. State
305 Conn. 360
| Conn. | 2012Background
- Sapko sought survivor's benefits under §31-306 after decedent Anthony Sapko died Aug. 18, 2006 from multiple drug toxicity due to overdose of Oxycodone and Seroquel, prescribed for work injuries and depression respectively.
- Decedent was a Connecticut Department of Correction employee with prior compensable injuries and ongoing treatment, including pain medications and psychiatric care.
- Computation of causation: commissioner found that decedent’s excessive ingestion of prescribed meds, not the work injuries themselves, broke the chain of causation to death.
- Board upheld the commissioner's superseding-cause finding; Appellate Court later held Barry abrogation applied only to tort negl igence, making the error harmless.
- Plaintiff argued Barry abrogated superseding-cause doctrine in workers’ compensation; appellate ruling treated Barry as not applicable to WC, and affirmed on harmless error theory.
- Court grants certification to review proximate-cause framework; ultimately affirms Appellate Court’s judgment, but on different reasoning, upholding the use of superseding-cause doctrine in WC context.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Barry abrogated superseding-cause doctrine in workers’ compensation cases. | Sapko argues Barry abrogates the doctrine for WC. | State contends Barry’s abrogation does not necessarily apply to WC. | Yes, superseding cause applies in WC; Barry abrogation not controlling here. |
| Whether the Appellate Court’s harmless-error analysis was correct. | Sapko contends improper Barry reading was reversible error. | State argues record supports proper application of law to facts. | Harmless error analysis affirmed; record supports proximate-cause outcome. |
| Whether Birnie’s substantial-factor standard governs WC proximate-cause. | Birnie requires more-than-de minimis contribution by employment. | Birnie’s standard not controlling to WC death-injury context. | Birnie does not control; WC proximate-cause analysis permits broader causation considered. |
| Whether the commissioner's finding that the overdose was a superseding cause was properly applied to break the chain. | Sapko claims decedent’s death tied to employment-related injuries. | State shows independent intervening cause due to overdoses not tied to employment. | Commissioner properly found superseding cause; proximate-cause theory satisfied. |
| Whether substantial-factor causation required in Birnie applies to this WC case. | Claimant insists employment must contribute more than de minimis to injury. | WC framework allows causation beyond de minimis under proximate-cause analysis. | Court adopts proximate-cause approach consistent with WC no-fault framework; Birnie-based threshold not required. |
Key Cases Cited
- Barry v. Quality Steel Products, Inc., 263 Conn. 424 (2003) (superseding-cause doctrine abrogated in tort, for reasons in Barry)
- Birnie v. Electric Boat Corp., 288 Conn. 392 (2008) (substantial factor standard; more-than-de minimis concept; context for WC)
- Archambault v. Soneco/Northeastern, Inc., 287 Conn. 20 (2008) (narrow exceptions to superseding-cause doctrine confirmed)
- Six v. Thomas O'Connor & Co., 235 Conn. 790 (1996) (proximate cause review framework in WC cases)
- Daubert v. Naugatuck, 267 Conn. 583 (2004) (causation standards and burden of proof in WC)