Could Worker Construct Compensable Claim from Bronchitis-Induced Buggy Crash?

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Imagine that an Alabama employee has a host of medical conditions that put him at risk for injury. If one of those conditions causes him to have an accident, can he still obtain workers’ compensation benefits? A case involving a construction company employee addresses that issue. 

The employee in that case had preexisting acute bronchitis, allergic rhinitis, and a heart condition that increased his risk of fainting. One day, he was driving his employer’s buggy when a construction vehicle pulled out in front of him. He inhaled the fumes, coughed severely, passed out, and slumped over in his seat. Meanwhile, the buggy accelerated and hit a shack, causing the employee’s exposed head to strike a metal box. 

The employer’s expert said that when the employee passed out, he was having vasovagal syncope as a result of the severe coughing. Deciding that the employee passed out and was injured because of an idiopathic (non-worked-related) condition, the company denied the claim.

The trial court disagreed, concluding that the injury was work-related because the design of the buggy contributed to the injury. The company appealed, arguing that the trial court didn’t use the right standard to determine that work conditions caused the injury. 

Under the "increased risk test," when an employee has a personal medical condition that contributes to an injury, the employee can still prove his claim is work-related if he shows that his employment conditions increased the risk of injury.

Did the trial court apply the right causation rule?

A. No. To succeed, the employee had to show that his personal health conditions didn’t contribute to the injury.

B. Yes. The buggy’s design was one of the factors that led to the injury.

If you selected B, you agreed with the court in MMR Constructors, Inc. v. Taylor, No. CL-2024-0979 (Ala. Ct. App. 10/24/25).

If you want the full text of this case, you want Simply Research

In Alabama, the court said, an employee can show that his job caused his injury even if the injury is caused partly by idiopathic factors. To do so, the employee just has to show that his employment conditions affirmatively contributed to the injury. This is the case even if the idiopathic condition was the primary cause.

So, while the injury in this case may have been caused by a personal medical condition, the claimant could still succeed by proving that his employment conditions increased the risk that he would get injured. Here, for example, the employee argued that the buggy’s design increased the risk that he would injure his head because the vehicle was not enclosed. 

The appeals court found that the trial court applied the right standard and correctly concluded that the claim met the increased risk test.

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