505 S.W.3d 805 (Mo. Ct. App. 2016)
Code(s): C007Accident; C030 Compensability; C031 Idiopathic Event
Factual
Background:
Employee
was pronounced dead at the scene of a one-vehicle crash. A witness to the
accident testified that he saw the truck move first from the right lane to the
passing lane, and then gradually into the median, without seeing any break
lights leading up to the accident. Employer’s medical expert indicated that
“heart attack, seizure, or other idiopathic event” were all possible causes of
Employee's injuries. He also thought that a “potential explanation” for what
happened would be anything limiting Employee's “ability to react”.
Commission Decision:
The
Commission clearly rejected the affirmative defense of an idiopathic condition,
citing lack of medical evidence that the employee experienced a “sudden medical
event”.
Analysis/Holding:
The
Court of Appeals believed that The Commission was correct in its ruling, based
upon the testimony of claimant’s expert that there was no medical evidence that
Employee experienced any “sudden medical event” that would have caused
incapacitation before the crash and no medical evidence that Employee was
peculiarly susceptible to a sleep or other inattentive disorders that could
have caused the crash.
The Takeaway:
The
Employer must be able to identify a sudden medical event that would have caused
the work injury. Circumstantial evidence - such as the witness’s testimony in
this case - is insufficient.