Unexplained Fall doesn’t Meet ‘Idiopathic Criteria,’ S.C. Top Court Rules

Case File

When a South Carolina worker took a tumble on her way to check email, the inability to pinpoint what caused her fall didn’t warrant a finding that its origin was idiopathic.

Case

Judy Marie Barnes v. Charter 1 Realty, №27479 (S.C. 01/14/15)

What Happened?

A worker tripped and fell at work while “hurrying” down the hall to check another employee's email. She experienced a broken left femur, a broken left humerus, and a torn rotator cuff.

The worker filed a claim for workers’ compensation. Evidence was introduced that her husband did not like the shoes the worker wore and had told her she needed to pick up her feet when she walked.

The single commissioner denied her claim, finding there was no explanation for the fall and it was not caused by some hazard at work or a deficiency in the carpet. The commissioner concluded that the worker’s fall was idiopathic.

The appellate panel affirmed, as did the court of appeals. The worker appealed to the South Carolina Supreme Court to consider whether the fall was idiopathic. The key issue was whether an unexplained fall, where no specific cause can be identified, should automatically be treated as an idiopathic fall.

Rule of Law

Under South Carolina law, idiopathic falls are excepted from the general rule that a work-related injury is compensable. An idiopathic fall is one that is brought on by a purely personal condition unrelated to the employment, such as a heart attack or seizure. The idiopathic fall doctrine is based on the notion that an idiopathic injury does not stem from an accident but is brought on by a condition particular to the employee that could have manifested itself anywhere.

What the South Carolina Supreme Court Said

According to the South Carolina Supreme Court, the appellate panel erred in concluding that the worker’s fall was idiopathic simply because she could not point to any cause of the fall.

“This reasoning does not comport with our jurisprudence of idiopathy,” the court wrote. “An idiopathic fall arises from an internal breakdown personal to the employee, thus negating any causal connection.”

The lower tribunals essentially reasoned that because no work hazard caused the fall, and because the worker could not identify why she fell, the fall must have been idiopathic. The South Carolina Supreme Court rejected that logic, holding that idiopathy requires affirmative evidence of a personal medical condition or internal failure causing the fall.

The court noted that there was no evidence that the worker’s leg gave or that she suffered some other internal breakdown or failure. It also noted that she did not faint or have a seizure.

“It is irrelevant that the carpet or the hallway was not defective,” the court wrote. “Whether she tripped because she was hurrying or she tripped over her own feet, neither is an internal breakdown or weakness that falls within the ambit of idiopathy.”

Verdict: The South Carolina Supreme Court reversed the court of appeals’ opinion affirming the panel’s denial of compensation and remanded for a determination of the appropriate award.

Takeaway

A finding that a fall is idiopathic is not warranted simply because a claimant is unable to point to a specific cause of her fall.

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