Washington County School District v. Labor Commission
358 P.3d 1091
Utah2015Background
- Steven Brown, a Washington County School District bus driver, suffered a compensable workplace lumbar disk injury in January 2003 (treated surgically) and returned to work in October 2004.
- He experienced recurrent back problems; MRI in March 2007 showed recurrent L4–5 disk extrusion affecting the right side as well.
- On September 1, 2007, at a public festival a child jumped on Brown, knocking him down; he developed severe bilateral radicular pain and required additional surgery in November 2007.
- Brown filed for workers' compensation for the 2007 injury; the ALJ, the Labor Commission, and the court of appeals found the 2007 injury was causally linked to the earlier compensable workplace injury and awarded benefits.
- Medical opinions agreed there was some causal connection but differed on its strength; one examiner (for the School District) described the prior workplace injury as only a minor contributing cause.
- The Supreme Court granted certiorari to clarify the causal standard for compensability of a subsequent non-workplace injury and remanded for application of that standard.
Issues
| Issue | Plaintiff's Argument (Brown) | Defendant's Argument (School Dist.) | Held |
|---|---|---|---|
| What causal link is required between an initial compensable workplace injury and a subsequent non‑workplace injury for workers' compensation? | The initial injury need only be a contributing cause (even a minor one) — the subsequent injury must be a natural result. | The initial injury must be the major cause (school district urged >50% standard). | The Court held the initial workplace injury must be a significant contributing cause of the subsequent injury under the direct-and-natural-results test (not merely de minimis; declined to adopt a >50% rule). |
| Whether the ALJ erred in refusing to convene a medical panel because of conflicting medical opinions on causation | Brown: no conflict requiring a panel; medical evidence supports causation. | School Dist.: medical opinions conflict and required panel referral. | Court declined to decide this issue on the merits and remanded for reconsideration under the clarified causation standard (ALJ to reassess need for a panel). |
Key Cases Cited
- Mountain States Casing Servs. v. McKean, 706 P.2d 601 (Utah 1985) (adopts Larson's direct-and-natural-results test for subsequent injuries)
- Makoff Co. v. Industrial Commission, 368 P.2d 70 (Utah 1962) (subsequent aggravation or "ripening" of prior industrial injury compensable when causally related)
- Perchelli v. Utah State Industrial Commission, 475 P.2d 835 (Utah 1970) (subsequent sneezing aggravation held compensable where evidence showed causal link to prior industrial injury)
- McKesson Corp. v. Labor Commission, 41 P.3d 468 (Utah Ct. App. 2002) (court of appeals characterization that prior accident must be a contributing cause; relied on below)
- Oliver v. Labor Commission & Employers' Reinsurance Fund, 318 P.3d 777 (Utah Ct. App. 2013) (court of appeals analyzed causal-link requirement and remanded for further factfinding)