Workers' Compensation in South Carolina: What Is An idiopathic Injury?

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If you are hurt while doing your job in Greenville, SC, you are entitled to apply for workers’ compensation benefits pursuant to the South Carolina Workers’ Compensation Act. The law prevents you from suing your employer directly for your workplace injury, so filing for workers’ compensation is your exclusive remedy. However, workers’ compensation law is detailed and nuanced. There are certain factual circumstances where benefits will be denied. One such circumstance concerns “ idiopathic” injuries. If your employer and the workers’ compensation insurance company proves your injury was purely idiopathic, then you will be denied benefits. On the other hand, if some idiopathic condition/injury contributes to your workplace injury, then you may be entitled to benefits after all. If you have been hurt at work in Greenville, SC, you are going to need the help of a good workplace injury lawyer like those at the law offices of David R. Price, Jr., P.A.

What Is An idiopathic Injury?

Man with chest pain brought on by workAn idiopathic injury is an injury that does not flow from an accident or some condition at the workplace, but, rather flows from a condition particular to the employee that could have manifested itself anywhere. Common examples are a heart attack or a seizure or embolism. Such injuries might happen at any time in any place — at home, while you are sleep, while you are fixing dinner, while you are watching television, etc. Employers argue that they should not have to pay workers’ compensation benefits if the work or the work environment played no role in the injury.

Workers’ Compensation In Greenville, SC: Older South Carolina Caselaw

There are a couple of older South Carolina cases where workers’ compensation benefits were denied based on the idiopathic injury doctrine. For example, in the case Crosby v. Wal-Mart Store, Inc., 499 S.E.2d 253 (Ct.. App.1998), the worker fell while walking through the store on her way to a meeting. She was unable to identify anything on the floor that caused her to fall. Since there was no any evidence of what caused her to fall, the court concluded it would be “wholly conjectural to say under the evidence presented that Crosby’s employment was a contributing cause of her injury.” As such, the court deemed the fall to be idiopathic and affirmed the denial of benefits. The court attributed her injury “to an internal breakdown within the claimant’s body where the claimant failed to present evidence as to the cause of the occurrence.”
A similar outcome was reached in a 1954 case, Miller v. Springs Cotton Mills, 225 S.C. 326 (S.C. 1954). In that case, the worker’s knee failed to function normally and she nearly fell as she rose from a chair in the workplace cafeteria. The court held that the evidence showed claimant’s knee failed to function normally, but it was not the result of any workplace abnormality or some condition of her work. The court affirmed the denial of workers’ compensation benefits, holding as follows:
“We have simply some internal failure or breakdown in the knee which might have happened at any time. The fact that it occurred in the cafeteria was purely coincidental. It would be wholly conjectural to say under the evidence before us that claimant’s employment was a contributing cause of her injury. To sustain an award of compensation in the instant case would necessitate opening the floodgates and holding that every internal failure suffered by an employee in the course of his employment becomes an accident just because it happens [at the workplace].”

Workers’ Compensation In Greenville, SC: New South Carolina Caselaw

In the last few years, the South Carolina Supreme Court has significantly changed the law with respect to idiopathic injuries. It is fair to say that under the old case law, if the worker could not identify some flaw or condition at the workplace that contributed to the injury, then essentially the worker was held to have had an idiopathic condition — an internal breakdown.
In the more recent cases, the South Carolina Supreme Court seems to have shifted the burden to the employer to prove some sort of internal breakdown or flaw in the worker. Thus, for example, in Barnes v. Charter 1 Realty, 768 S.E.2d 651 (S.C. 2015), a worker stumbled, fell, and sustained serious injuries while walking to a desk to check her email. She was unable to point to any cause of her fall, and there was no irregularity in the office carpeting. Under the old caselaw like Crosby, failing to show evidence of a flaw in the carpet would have led to a finding of idiopathic injury. However, despite the unexplained nature of the fall, the court concluded that the injuries were not idiopathic because there was “no evidence [that claimant’s] leg gave out or she suffered some other internal breakdown or failure.”
A similar result was reached inForan v. Murphy, USA, Opinion No. 5491 (Ct. App. June 14, 2017). In that case, a worker was stocking cigarettes and as she rose her ankle twisted and she fell sustaining injury. The WC Commission held the case to be like Miller, above, saying that there was some internal flaw in the worker’s ankle and therefore it was an idiopathic injury for which benefits were not available. The medical records showed that the worker had surgery in the past on the same ankle. In opposition, the worker claimed to have caught her foot on a mat that was on the floor and the mat caused her to fall. The Court of Appeals reversed the Commission, holding that the evidence clearly showed the floor mat’s role in the worker’s fall.

Greenville SC Workers’ Compensation Lawyer: David R. Price, Jr. P.A.

As can be seen by these cases, workers’ compensation claims can be very fact intensive. In reviewing the evidence in the Foran case, above, the court focused on whether the worker’s feet were both flat on the floor or were moving when she fell. Clearly, attention to detail is very important. If you have been hurt at work, call the skilled Greenville SC workers’ compensation lawyers at David R. Price, Jr., P.A. We have the necessary attention to detail to help you with your workers’ compensation claim. Our attorneys know South Carolina workers’ compensation law and are courtroom-proven. Email or call us today at (864) 271-2636 about your case.


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