The Appellate Group

Ackley v. Labor Commission

Ackley v. Labor Commission, 2021 UT App 42 (Christiansen Forster)

Workers Compensation

An employee had a ganglion cyst on her hand. As she was putting away a hammer, the hammer slipped and she grasped it more tightly, felt extreme pain, blacked out, fell, and was injured. She sought workers’ compensation benefits, which the Labor Commission denied, reasoning that gripping the hammer did not involve unusual or extraordinary exertion and that the idiopathic fall doctrine did not apply. The Utah Court of Appeals reversed, holding:

  • Under the idiopathic doctrine, an employee’s injuries stemming from a fall that was caused by reasons that are personal to the employee (such as a heart attack, seizure, or a fainting spell) are compensable if the employment conditions increased the dangerous effects of the fall. With this doctrine, employees are not required to show an increased risk of injury; rather, they must show that the workplace conditions aggravated the dangerous effects of a fall or the injuries that resulted from it. In this case, the Commission erred by not analyzing the employee’s injuries under the idiopathic fall doctrine.

Read the full court opinion