Is a Workplace Injury Caused by a Non-Occupational Medical Condition Compensable? Connecticut Appellate Court says “Yes” in Clements v. Aramark Corporation
It is a fundamental principle of Connecticut workers’ compensation law that in order for an injury to be compensable, it must occur in the course of and arise out of the claimant’s employment. In the recent Appellate Court decision of Clements v. Aramark Corp., the court considered whether an employee who fell and injured herself at work due to an unrelated medical condition met this burden. In a critical decision that overturned both the Trial Commissioner and Compensation Review Board (CRB), the court found in favor of the employee, further muddying an already unclear area of the law.
Ms. Clements, who has a preexisting conditional known as cardiogenic syncope, was walking into work when she suffered a cardiac episode, fainted, and fell to the ground, injuring her head. She did not trip or slip, and there were no witnesses to the incident. Both the Trial Commissioner and CRB concluded that her injuries were not compensable because they were due to cardiogenic syncope and not her job. In other words, her preexisting medical condition caused her injuries, not her employment.
The Connecticut Appellate Court reversed in Clements v. Aramark Corp., et al., 182 Conn.App. 224 (2018). Specifically, the Appellate Court held that Ms. Clements’ injury was compensable because “although the personal infirmity that caused her to fall did not arise out of her employment, the resultant injury . . . did arise out of her employment.” In reaching this conclusion, the court relied heavily on the 1937 case of Savage v. St. Aeden’s Chuch and its more modern iteration, Blakeslee v. Platt Brothers, Inc., discussed briefly below.
In Savage, the claimant, who was a painter, fell while at work, fractured his skull and died. The precise cause of his fall was unknown, though it was likely due to a heart attack or fainting spell. The court concluded that Mr. Savage’s death was compensable despite that the fall may have been precipitated by an underlying medical condition because, as the court stated, “the possibility of a fall while engaged in his work was one of the hazards of his employment.” Savage v. St. Aeden’s Church, 122 Conn. 343 (1937).
In the more recent case of Blakeslee v. Platt Bros., the claimant suffered a seizure at work and two coworkers attempted to aid him, resulting in injuries to his shoulders. The court found Mr. Blakeslee’s injuries to be compensable, primarily on the ground that the aid rendered to Mr. Blakeslee was for the benefit of both the employee and the employer. Blakeslee v. Platt Bros. and Co., 279 Conn. 239, 250-51 (2006).
In addition to its interpretation of Savage and Blakeslee, the court relied heavily on what it deemed to be “the humanitarian and remedial purposes of the act,” which “counsel against an overly narrow construction that unduly limits eligibility for workers’ compensation.” However, using the Appellate Court’s logic, conceivably any fall at work – whether or not it is actually caused by the claimant’s employment – could be considered compensable. While Connecticut Courts and the CRB have long-held that the Connecticut Workers’ Compensation Act is intended to be broadly construed, such a far-reaching holding surely could not have been the intent of the Act.
With the above in mind, when analyzing the compensability of a claim caused by an unrelated medical condition, the Connecticut claim professional should be aware of the decision in Clements and how it limits the practicable applicability of this defense.
The Respondents have petitioned the Connecticut Supreme Court for review. As of the date of this publication, the court has neither certified nor denied the petition. Stay tuned for future updates on this important area of the law.