What is the ‘Idiopathic Fall Doctrine’ in Utah?

Do You Know the Rule?

Ogden, UT (WorkersCompensation.com) – In Utah, for the idiopathic fall doctrine to apply, a condition of the employee’s work must actually aggravate the injury the worker sustains. The presence of conditions that increased the risk of injury is not sufficient. 

A case involving a Lowe's worker, Ackley v. Labor Commission, No. 20220966-CA (Utah Ct. App. 08/22/24), caused a Utah court to recently make that clarification. In that case, the worker was on a ladder above a concrete floor in the store when she squeezed a hammer. That caused a cyst on her finger to rupture, resulting in severe pain.  

Looking for the full text of the Ackley decision? Head to Simply Research.

The employee lost consciousness and fell off the ladder, striking the concrete. She suffered severe injuries, including a closed head injury, a torn rotator cuff, a non-healing scalp lesion, hearing loss, and left-shoulder pain. 

Lowe’s opposed her worker’s compensation claim, arguing that the injury stemmed, not from work, but from a preexisting condition.  

The court explained that, under the idiopathic fall doctrine, a fall originating from an employee’s internal or personal weakness or condition is considered "idiopathic."  

Whether an injury resulting from an idiopathic fall is compensable depends on whether the employee’s employment conditions increased the severity of the injury that resulted from the fall. If they did not, then the employment and injury are not causally linked, and the injury is not compensable. 

To increase the risk, the employment conditions must in some way contribute to or aggravate the injury, the court explained. The mere possibility of an increased risk of injury is not sufficient. Instead, the conditions must actually contribute to the injury.  

“We take this opportunity to clarify that, by referencing ‘increased risk’ in our previous opinion, we did not intend to indicate that the mere presence of unactualized risk means that all injuries from an idiopathic fall are compensable,” the court wrote.  

“[I]diopathic falls to level ground on a hard floor might be compensable, but only if the employee can show, as a factual matter, that the hardness of the floor made the resulting injuries worse.” 

Here, working above hard surfaces was clearly one of the employee’s job duties. And on the day she was injured, she was engaging in those duties. 

Thus, the question the workers' compensation commission needed to address was whether the condition of Lowe's concrete floor aggravated the effects or severity of the employee’s injuries. The court sent the case back to the commission to make that determination, based on the facts. 

Share This Article: