Non-“work related” injuries at work

Under current Connecticut Workers’ Compensation law, injuries from personal medical conditions unrelated to the workplace or work activities may not be the basis for Workers’ Compensation benefit.  In order for an injury to be covered by Workers’ Compensation it must “arise out of employment and in the course of employment”. 

The Connecticut Supreme Court has found that medical incidents which are of a chronic or personal nature do not meet the requirement of “arising out of” employment even if they occur in the workplace.  In Clements v. Aramark Corporation, a worker sustained a head injury in the workplace after fainting as a result of a chronic heart condition.  The heart condition was unrelated to work.  The fall occurred while working on a flat surface away from any hazardous objects.  The Supreme Court found that the heart condition was a “personal infirmity”.  They held that falls sustained because of such personal medical conditions were “idiopathic” falls and did not warrant an award of Workers’ Compensation benefits.

However, despite the Court’s decision in Clements, injuries from personal medical conditions occurring at work may still qualify for Workers’ Compensation benefits depending on the circumstances.  An idiopathic fall that is worsened by the nature of the workplace is likely to qualify for Workers’ Compensation benefits.  For example, in Gonier v. Chase Companies, an injured worker was allowed to collect Workers’ Compensation when he suffered a fainting incident and subsequently fell off scaffolding.  An incident where someone falls onto an object, such as a table or machine that worsened the severity of a fall would also likely be found to be compensable.  In Clements, the Court even left open the possibility that the hardness of the floor could be a sufficient basis for Workers’ Compensation benefits.

Unfortunately, following the Clements decision, insurance companies will likely try to fight workplace injuries involving personal medical conditions.  Consulting an experienced Workers’ Compensation lawyer can help increase the chances that these types of injuries will be awarded Workers’ Compensation benefits.