The Workers’ Compensation system is predicated on the notion that employees, regardless of fault, should be compensated for injuries they sustain at work. However, the Ohio Second Appellate District Court recently stated that while this is generally the case, there is one exception to the rule — unexplained falls.
In White v. Buehrer, an employee fell while walking through an examination room to deliver mail. Her workplace injuries included a broken right hip. In her claim for Workers’ Compensation, the employee stated that she fell because the floor was “tacky,” a statement that was refuted by one of her co-workers who testified that the floor was not hazardous in any way.
The Ohio Industrial Commission denied her claim and the employee appealed, filing a motion for summary judgment to the common pleas court. In her motion, she stated that her injury occurred at work, the injury was explained by a workplace condition (the tacky floor) and that none of the exceptions to compensation (horseplay, intoxication, idiopathic conditions, etc.) applied. The trial court granted her motion, but the Second Appellate District reversed the decision, denied her motion of summary judgment and remanded the case to the trial court.
The Second Appellate District Court cited a precedential case in which a claimant fell while going down the stairs at work. There was no evidence of a hazard that could have contributed to his fall. The court in that case held that in unexplained fall cases, the worker has the burden of showing that his or her fall was not the result of idiopathic causes. In White, it was determined from the employee’s medical records that an idiopathic factor may have contributed to her fall, which she failed to show was not the cause of her fall. Therefore, the employee in this case will not receive Workers’ Compensation benefits to help cover the cost of her workplace accident because it was an unexplained fall that may have been caused by idiopathic factors.
Source: supermecourt.ohio.gov, “White v. Buehrer,” accessed Nov. 9, 2017