NCCI Court Case Update: Utah

On August 22, 2024, the Utah Court of Appeals, in Ackley v. Labor Commission, clarified that injuries resulting from idiopathic falls to level ground floors can be compensable if the employee can show that the hardness of the floor made the resulting injury worse.

In this case, an employee suffered multiple injuries after falling to a level ground floor at work. The fall was prompted by a ruptured hand cyst, which caused extreme pain and loss of consciousness. The court of appeals, in its initial review of the case, determined that the employee's fall was idiopathic as it originated from the employee's "internal or personal weakness or condition" and remanded the case to the Utah Labor Commission to consider whether the work conditions contributed to the hazards of the fall and increased the risk of injury to render the injury compensable. On remand, the commission denied benefits, reasoning that the evidence did not support the conclusion that the employment placed the employee in a position that increased the dangerous effects of the idiopathic fall.

The commission's decision was again appealed, and the court of appeals clarified that in an analysis of compensability for an idiopathic fall, an "increased risk" alone is not enough. Instead, the risk must actually result in increased or aggravated injuries. Thus, the court concluded, idiopathic falls to level ground floors may be compensable, but only if the employee can show that the work conditions—in this case the hardness of the floor—made the resulting injuries worse.

For more information on other cases monitored by NCCI's Legal Division, visit previous Court Case Updates and Court Case Insights under the Legal section of INSIGHTS on ncci.com.

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