The Compensability of Idiopathic Falls: Did the Fall Arise Out of the Employment?

In order to be compensable, an injury must both “arise out of” employment and occur “in the course of” employment. Every employer, not specifically excepted by the provisions, must provide, secure, and pay compensation according to the provisions of the Act for any and all personal injuries sustained by an employee arising out of and in the course of employment. IOWA CODE §85.3(1). Both tests must be satisfied for an injury to be deemed compensable.

“Arise out of” – An injury “arises out of” the employment if a causal connection exists between the employment and the injury. Meyer v. IBP, Inc., 710 N.W.2d 213 (Iowa 2006). Thus, the “arising out of” employment element means there must be a causal relationship between the injury and the “…general and incidental requirements or duties contemplated by the employer.” Crowe v. De Soto Consol. School Dist., 68 N.W.2d 63 (Iowa 1995).

“In the course of” – The injury arises “in the course of” the employment when the injury and the employment coincide as to time, place, and circumstances. Sheerin v. Holin Co., 380 N.W.2d 415 (Iowa 1986); McClure v. Union County, 188 N.W.2d 283 (Iowa 1971). Thus, the “in the course of” employment element is satisfied when the injury takes place within the period of the employment, at a place where the employee reasonably may be, and while the employee is fulfilling work duties or engaged in doing something incidental thereto. Meyer v. IBP, Inc., 710 N.W.2d 213 (Iowa 2006).

Idiopathic Falls – Generally, if an injury is a result of a risk personal to the claimant, the injury is not compensable. Koehler Elec. v. Wills, 608 N.W.2d 1 (Iowa 2000). An example of this may be a fall due to a temporary loss of consciousness caused by a personal medical condition.

There is an exception to this rule, however. An employee’s injury sustained via an idiopathic event may be compensable if the employment contributes to the injury. Id. A claimant “…must prove … that a causal connection exists between the conditions of his employment and his injury….” Benco Mfg. v. Albertsen, 764 N.W.2d 783 (Iowa Ct. App. 2009). In order for an idiopathic fall to “arise out of the employment,” the injury must be a natural incident of the work, meaning the injury must be a rational consequence of the hazard connected with the employment. Koehler Elec. v. Wills, 608 N.W.2d 1 (Iowa 2000).

For example, if the employment places the employee in a position increasing the risk to the employee, such as working at a height, around machinery, near sharp corners or in a moving vehicle. Id. The injury must not have coincidentally occurred while at work, but must in some way be caused by or related to the working environment or the conditions of employment. Id.

For questions, please contact Iowa Workers’ Compensation Attorney Emily R. Motto at emotto@baylorevnen.com or 402-475-1075 to speak with any of Baylor Evnen’s Iowa Workers’ Compensation Attorneys.