Utah American Energy Inc., and Rockwood Casualty Ins. Co. Inc. v. Labor Commission and Adam Pilling
Utah American Energy Inc., and Rockwood Casualty Ins. Co. Inc. v. Labor Commission and Adam Pilling, 2021 UT App 33 (Harris, J.).
The Labor Commission of Utah awarded Employee permanent total disability benefits after he sustained a head and neck injury at work. His employer, Utah American Energy (UAE) and its insurer sought review of the Commission’s Award. They argued that Employee had not sustained a significant industrial impairment that was the direct cause of the permanent total disability. The Court of Appeals affirmed, holding:
- The Commission correctly interpreted the relevant statutory provisions, including Utah Code § 34A-2-413(1)(b)(i), which “requires an injured worker to prove that he or she suffered a ‘significant impairment or combination of impairments as a result of’ the specific accident (or disease) ‘that gives rise to’ the claim for permanent total disability benefits,” and which “does not require the worker to demonstrate a causal link between the impairment and the permanent total disability.”
- The Commission properly applied the facts of the case to the Utah Code in reaching its conclusion that Employee had suffered a significant impairment because of the work accident.