535 S.W.3d 336 (Mo. 2017)
Full Opinion: [White v. ConAgra]
Code(s): C002 Medical Causation; C007 Accident; C030 Compensability; C031 Idiopathic Event
Factual
Background:
Employee
was working outside as a machinist on a very hot day, when he died of a
cardiovascular event. He had several cardiac risk factors, including HBP,
cardiac enlargement, evidence of coronary artery disease, and he was a smoker.
The ALJ denied compensation, noting that it was not established that the
employee’s work activities were the prevailing factor in causing his cardiac
arrest.
Commission/Missouri
Court of Appeals Decision(s):
The
Commission affirmed the denial but in their Final Award determined that
Employee’s death at work was an “accident” since it was a “sudden traumatic
event” but the Commission agreed that the widow failed to sustain her burden of
proof on causation. The Court of Appeals issued a detailed opinion in which
they remanded the matter to the Commission.
Analysis/Holding:
On appeal, the Court noted that under Sec. 287.020.3(4) for a cardiovascular
disease or myocardial infarction to be compensable there must be showing that:
(1) there was an “accident”; (2) there was an “injury”; and, (3) the former was
the prevailing factor in causing the latter. The Court then discussed, but
found as unpersuasive, the widow’s arguments as to requirements (1) and (2) but
instead focused on her failure to prove that the accident was the prevailing
factor in causing the employee’s injury (death).
The Takeaway:
This case is an acknowledgment of the Commission’s power to determine the weight to be given to the testimony of competing experts in a case which involved medical issues which are beyond lay understanding.