This case requires the court to decide the circumstances under which an idiopathic fall is compensable under Iowa’s workers’ compensation law. The district court affirmed the industrial commissioner’s decision that thе injuries sustained by the appellee, Carlton Wills, in an idiopathic fall at his place of employment, arose out of and in the course of his employment. We affirm the district court’s decision.
I. Background Facts and Proceedings.
Carlton Wills had worked for the аppellant, Koehler Electric, for two days when he fell from a ladder while wiring a customer’s air conditioning unit. Wills sustained serious head and shoulder injuries in the fall. He subsequently filed a claim for workers’ compensation benefits thаt was opposed by Koehler and its insurer, appellant, Continental Western Insurance. (We will refer to these parties jointly as Koehler.) Koehler asserted that Wills’ injuries did not arise out of his employment because his fаll was the result of alcohol withdrawal.
The evidence introduced at the hearing showed that Wills appeared to be unconscious when he fell and that witnesses observed him convulsing as he lay on the floor. Wills experiеnced delirium tremens in the hospital and was diagnosed as suffering from delirium tremens and alcoholism, as well as head and shoulder injuries.
The deputy industrial commissioner awarded medical benefits for the injuries Wills sustained in the fall, finding that “the fall was greatly aggravated by the fact that it occurred five feet above the ground while working on a ladder.” Koehler appealed the deputy’s decision to the industrial commissioner, arguing that Wills had failed to show that his injuriеs were actually enhanced by the four to five foot fall from the ladder and that such proof was required to show that the injuries arose out of his employment. The commissioner rejected Koehler’s argument and affirmеd the award of benefits, stating:
In the present case, the cause of claimant’s fall was alcohol withdrawal. The alcohol withdrawal is akin to an epileptic fit or a fainting spell. His work required that he be on a laddеr four to five feet off the floor. He fell onto a cement floor. Claimant’s employment or working environment placed him in a position that increased the effects of his fall. The injury resulting from claimant’s fall arose out of his employment.
On judicial review to the district court, the commissioner’s award of benefits was affirmed. The case is now before us on Koehler’s appeal.
II. Scope of Review and Issue on Appeal.
Our review is limited to correction of errors of law.
See 2800 Corp. v. Fernandez,
The sole issue on appeal in this case is whether there was substantial evidence to support the commissioner’s conclusion that Wills’ injuries arose out of his employment with Koehler. The resolution of that issue turns on whether Wills’ case was fatally deficient because it lacked any evidence that Wills’ injuries were in fact worse because he fell from a height. We turn now to a review of the governing legal principles.
III. Applicable Law.
A.
General principles governing workers’ compensation claims.
Iowa Code chapter 85 provides in pertinent part: “Every employer, not specifically excepted ..., shall provide, secure, and pay compensation according to the provisions of this chapter for any and all personal injuries sustained by an employee
arising out of and in the course of
the employment.” Iowa Code § 85.8(1) (1995) (еmphasis added). The burden is on the claimant to prove both that the injury “arose out of’ and “in the course of’ his employment.
See Miedema v. Dial Corp.,
An injury “arises out of’ the employment when there is a causal relationship between the employment and the injury. The injury must be a “rational consequence of the hazard connected with the employment.” “In the course of’ the employment refers to the time, place, and circumstances of the injury.
Fernandez,
In the casе at hand, there is no dispute that Wills’ injuries occurred in the course of his employment. Wills was where his employer had directed him to be and was performing his required job duties at the time of his fall.
See Miedema,
Injuries that occur “in the course of’ employment do not, however, necessarily “arise out of the employment.”
See id.
As noted above, there must be a causal connection between the injury and the employment. “In other words, the injury must not have coincidentally occurred whilе at work, but must in some way be caused by or related to the working environment or the conditions of ... employment.”
Id.
(concluding that despite the fact that the employee’s back strain occurred in the course of employment, the fact that the employee strained his back while using the restroom was not a hazard associated with his employment and thus did not arise out of his employment). “ ‘The injury must be a natural incident of the work[;] ... it must be a rationаl consequence of a hazard connected with the employment.’ ”
Id.
(quoting
Cedar Rapids
The analysis in the present case is complicated by the fact that the commissioner found that Wills’ fall was not precipitated by any condition connected with his employment; rather it was caused by a condition purely personal to Wills — his alcohol withdrawal. Courts from other jurisdictions have held that falls resulting from alcohol withdrawal are idiopathic in nature.
See Evans v. Hara’s, Inc.,
B.
Compensability of idiopathic falls.
Genеrally injuries resulting from-risks personal to the claimant are not com-pensable.
See Evans,
Koehler asserts that, in order to fall within this exception, a claimant must prove that the injuries he sustained were worse as a result of the height from which he fell, than they would have been had he fallen on level ground. Koehler argues that Wills failed to meet this burden of proof because he offered no expert testimony that his injuries were enhanced by the fall from five feet.
See Bradshaw v. Iowa Methodist Hosp.,
Initially, we note that to adopt Koehler’s position would essentially require the claimant to prove what portion of his injuries was caused by the work-related condition' — the increased height — and what portion would have been sustained had he fallen at ground level. But such apportionment is not required. As Larson states in his treatise,
the relative contributions of employment and personal causes are not weighed; the employment factor need not be the greater, but it must be real, not fictitious. When a moderate exertion precipitates a heart attack or back injury, or when a secluded employment setting facilitates a privately motivated murder, who can weigh the causal factors and say that the employment contribution was ten percent and the personal contribution ninety percent? Compеnsation law attempts no such impossible weighing of intangibles. But it does know the difference between something and nothing, and it rightly requires that the employment contribute something to the risk, before pronouncing the injury one arising out of the emрloyment.
Workmen’s Compensation Law
§ 12.14(b), at 3-371 (emphasis added). Focusing on whether the employment increases the
risk of
injury is consistent with our discussion in
Miedema
with respect to when an injury “arises out of’ the worker’s employment. In
Miedema,
the employee injured his back while using the restroom at his place of employment.
In reviewing cases from othеr jurisdictions, we find no court that has based compensability on proof by the claimant of the precise injuries that were caused by the workplace condition, such as the elevation from which the claimant fell. Rаther these courts have focused on the increased risk of injury, or have concluded summarily that a fall from a height increased the effects of the fall.
See, e.g., ERC Contractor Yard & Sales v. Robertson,
In conclusion, we hold that it is not necessary for a claimant injured in an idiopathic fall to prove that his injuries were worse because he fell from a height. It is only required that he prove that a condition of his employment increased the risk of injury. In this case, expert testimony was not essential because the fact finder could conclude based on common experience that the risk of injury is greater when one falls from a height of four to five feet onto a concrete floor than when one falls on level ground.
See Howard v. Ford Motor Co.,
AFFIRMED.
