Columbus, Georgia Lawyer Mark Jones Discusses Two Cases on Idiopathic Injuries in Workers Compensation Cases
Three Cases on Idiopathic Injuries in Workers Compensation Cases
Sometimes in representing clients in workers compensation claims in Columbus, Georgia / Muscogee County, defense counsel or the workers compensation adjuster will raise a defense to a workers compensation claim calling the cause of the injury, “idiopathic.” These type of defenses are common concerning workers compensation claims involving fall down injuries such as a slip and fall or trip and fall on the job. This blog discusses this defense and two appellate decisions explaining this defense.
Definition of Idiopathic Injury:
Idiopathic injuries are injuries where the cause of the injury is something peculiar to the employee’s physical or mental state. The concept if sometimes conflated with a work injury where the cause of a fall is unclear. (i.e., “I don’t know why I fell.”).
Two Cases Explaining Idiopathic Injuries:
Peachtree: Great Deference to ALJ (The Ying)
In Harris v. Peachtree County Board of Education, (2009) a morbidly obese custodian bent over to pick up her own pill off the floor and blew out her back. The idiopathic defense was raised.
The Administrative Law Judge with the State Board of Workers Compensation found that the claim was compensable since picking trash up off the floor was in furtherance of the employee’s job duties. The Court noted the great deference they would give to an ALJ on the issue of whether an employee’s injury arises out of the course and scope of the employment.
St. Joseph’s Hospital: Great Deference Given to the ALJ: (The Yang)
In contrast, in St. Joseph’s Hospital v. Ward, 300 Ga. App. 845 (2009) a nurse injured her right knee when she went into patient’s room to give medication and while turning to get patient some water, twisted her right knee and felt a pop in her right knee. The State Board of Workers Compensation held that this claim was not compensable. The Court of Appeals noted the great deference they gave to an Administrative Law Judge’s findings in cases where causation appears to be idiopathic or unclear.
Cases involving idiopathic injuries are resolved on a case-by-case basis, much like slip and falls are in personal injury cases. These type of cases require counsel experienced in workers compensation matters. Lawyer Mark Jones is experienced in workers compensation cases in Columbus, Georgia and Muscogee County. Call him today for a free consultation at 706-225-2555.