Death Or Injury Easier To Prove In Workers’ Compensation Cases
The Supreme Court of California recently decided South Coast Framing Inc. v WCAB—an important case in workers’ compensation law. The decision clarifies how evidence should be weighed in workers’ compensation cases.
A carpenter working for South Coast Framing suffered neck and back injuries and a concussion while on the job. He was prescribed medications by both his Workers’ Compensation doctor and his personal physician—and tragically died of an accidental overdose. His family sought death benefits through the Workers’ Compensation system and a Workers’ Compensation Judge granted those death benefits. The Court of Appeal reversed that decision. Ultimately, the Supreme Court of California reversed that decision and reinstated the death benefit award.
While the medical evidence found that it was primarily because of the drugs prescribed by his personal physician, the medical expert conceded that at least one of the medications from the Workers’ Compensation doctor contributed to the overdose. Additionally, the medications prescribed by the personal physician were to help with sleep problems the deceased worker had started suffering since the work accident. The Workers’ Compensation Judge ruled, therefore, that the fatal overdose was tied to the work accident.
The Court's Decision
The Court of Appeal, on the other hand, ruled that there was a lack of evidence to support this finding. The issue is in the language of the actual Labor Code and that there are different standards of causation in workers’ compensation than in tort (personal injury) law. The Court of Appeal was using a standard more applicable to a suit brought in civil court—in that the impact of the medications from the workers’ compensation doctor were not “significant” enough to prove causation.
In its overturn, the California Supreme Court correctly pointed out that, because of the way the state’s labor code is written, the Court of Appeal applied the wrong standard for a death case. In the Workers’ Compensation system, it is sufficient to prove that employment is a contributing cause to the death—not the amount of the contribution. Furthermore, the Supreme Court ruled that a Workers’ Compensation Judge’s findings of fact are not subject to appellate review at all if the findings are supported by the totality of the evidence and of the record; the Court of Appeal is “not free to reweigh the evidence or substitute an inapplicable standard of review.”
The End Result
The end result of all of this is that it helps clarify what the standard of causation is in a workers’ compensation cases. Although the decision specifically dealt with a family seeking death benefits for an injured worker, the clarified standards should help any worker trying to establish that an injury or illness is work related.
If you have a Workers’ Compensation legal issue, we at The Law Offices Of Maurice L. Abarr are uniquely qualified to assist you. Contact us for a free consultation.
NOTICE: Making a false or fraudulent Workers Compensation claim is a felony subject to up to 5 years in prison or a fine of up to $50,000 or double the value of the fraud, whichever is greater, or by both imprisonment and fine.