Utah American Energy v. Labor Commission
2021 UT App 33
| Utah Ct. App. | 2021Background
- In May 2007 Pilling struck his head on a steel beam at work; he had preexisting chronic low‑back and hip pain.
- After the accident he developed neck, jaw (TMJ), back, and upper‑extremity pain; imaging largely normal but clinicians noted a healed cervical compression.
- UAE previously stipulated in Commission proceedings that some spinal surgery and partial disability were work‑related; Pilling later sought permanent total disability benefits (filed 2014, amended 2015).
- Conflicting medical and vocational opinions led the ALJ to refer the matter to a medical panel; the panel found the Work Accident medically caused cervical and TMJ injuries and assigned a 16% whole‑person impairment (13% cervical, 3% TMJ).
- The ALJ and the Labor Commission credited the panel, found Pilling suffered a "significant impairment" from the accident, and held the accident was the "direct cause" of his permanent total disability; UAE appealed.
Issues
| Issue | Pilling's Argument | UAE's Argument | Held |
|---|---|---|---|
| Whether Utah Code §34A‑2‑413(1)(b)(i) requires the impairment to "give rise to" the permanent total disability (i.e., whether subsection (i) requires a causal link between the impairment and the permanent total disability) | Subsection (i) requires only that the worker sustained a significant impairment "as a result of" the specified industrial accident. | Subsection (i) also requires the worker to show the impairment itself "gives rise to" the permanent total disability (an additional causation requirement). | Court held subsection (i) requires only that the impairment be causally related to the specific accident; the statutory causation requirement to connect the accident to permanent total disability appears in subsection (iii). |
| Whether the Work Accident was the "direct cause" of Pilling's permanent total disability when non‑industrial preexisting conditions also contribute | The accident need only be a contributing cause; the medical panel establishes medical causation and Pilling’s condition is not solely from preexisting problems. | Medical causation requires the accident be the sole, primary, or dominant cause of the disability (preexisting conditions sever the causal link). | Court held medical causation is satisfied if the accident is a but‑for/cause in any degree (not necessarily the sole or dominant cause); substantial evidence (medical panel report) supports the Commission’s direct‑cause finding. |
Key Cases Cited
- Provo City v. Utah Labor Comm’n, 345 P.3d 1242 (Utah 2015) (explains the statute’s causation analysis and that medical causation requires accident be a but‑for cause)
- Fogleman v. Labor Comm’n, 364 P.3d 756 (Utah Ct. App. 2015) (discusses significant‑impairment inquiry being individualized and causally related to the work accident)
- Cox v. Labor Comm’n, 405 P.3d 863 (Utah Ct. App. 2017) (medical causation satisfied if accident contributed in any degree; not solely the preexisting condition)
- Hutchings v. Labor Comm’n, 378 P.3d 1273 (Utah Ct. App. 2016) (medical causation is a factual question reviewed for substantial evidence)
- Benson v. Utah Labor Comm’n, 437 P.3d 1253 (Utah Ct. App. 2018) (a medical panel’s report can constitute substantial evidence supporting medical causation)
- Oliver v. Utah Labor Comm’n, 424 P.3d 22 (Utah 2017) (standard of review for statutory interpretation of Labor Commission rulings)
- Bryner v. Cardon Outreach, LLC, 428 P.3d 1096 (Utah 2018) (statutory interpretation principles; consider plain language and context)
- State v. Jeffries, 217 P.3d 265 (Utah 2009) (canon against construing statutes so parts are superfluous)