Shea v. State, Department of Administration, Division of Retirement & Benefits
267 P.3d 624
| Alaska | 2011Background
- Shea underwent 1984 nerve-damage surgery with intermittent pain thereafter.
- Shea began state employment in 1993, requiring prolonged sitting at a desk.
- Pain worsened 1997–1998; by 2001 she left work due to chronic pain.
- Shea sought both nonoccupational and occupational disability benefits; the ALJ found sitting was a factor but not of substantial significance.
- Superior Court upheld the ALJ; Alaska Supreme Court remanded to reevaluate causation under a defined substantial-factor standard.
- Key medical opinions (Beard, Smith, Cole, Blocher) formed the evidentiary basis for the ALJ’s causation findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was employment a substantial factor in causing disability? | Shea contends prolonged sitting materially aggravated her pain and was a substantial causal factor. | Other daily activities equal to or exceed sitting in contributing to pain; sitting not a substantial factor. | Remand to reapply the substantial-factor standard. |
| Did the ALJ properly interpret Dr. Smith's testimony on causation? | Smith testified sitting likely aggravated the condition; ALJ misrepresented him as only noting possible aggravation. | Smith’s testimony was limited and not conclusive; other evidence undermines causation. | Remand needed to reassess Dr. Smith’s testimony under substantial-factor standard. |
| What is the proper substantial-factor standard for occupational disability in Alaska? | Prolonged sitting can be a substantial factor even if not sole cause. | Requires a defined standard consistent with Alaska authorities; not every contributing factor suffices. | Adopt and apply the substantial-factor causation framework with cause-in-fact and proximate-cause elements; remand for reconsideration. |
Key Cases Cited
- State v. Abbott, 498 P.2d 712 (Alaska 1972) (substantial-factor and legal-cause concept in torts)
- State, Pub. Emps. Ret. Bd. v. Cacioppo, 813 P.2d 679 (Alaska 1991) (incorporated substantial-factor standard into occupational disability)
- Fairbanks N. Star Borough v. Rogers & Babler, 747 P.2d 528 (Alaska 1987) (defining substantial-factor in occupational context)
- Hester v. State, Pub. Emps.' Ret. Bd., 817 P.2d 472 (Alaska 1991) (substantial evidence and review standard in admin decisions)
- Lopez v. Adm'r, Pub. Emps.' Ret. Syst., 20 P.3d 568 (Alaska 2001) (substantial-evidence standard in AK administrative review)
- Doyon Universal Servs. v. Allen, 999 P.2d 764 (Alaska 2000) (clarified substantial-factor causation standard and evidence review)
- State, Pub. Empls. Ret. Bd. v. Saling (Ketchikan Gateway Borough v. Saling), 604 P.2d 590 (Alaska 1979) (last injurious exposure rule discussion and substantial-factor concept)
- Var. Alaska references, N/A (Alaska 1991–2011) (contextual authority for causation framework in occupational-disability cases)