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Campbell v. Trees Unlimited, Inc.

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. 

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