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It can be a disheartening fact of life for employers that, even when they do everything right and follow all applicable safety rules and regulations to the letter, employee injuries can still happen. It is also often frustrating that those injuries, even in the absence of any wrongdoing by the employer, will result in workers’ compensation claims that can adversely impact the employer in a variety of ways. Is there anything employers can do to defend themselves against those claims involving injuries that seem to have just happened with no apparent explanation or associated hazard as the cause? Yes, actually—if the injury was the result of an idiopathic cause.
Under Ohio Workers’ Compensation law, idiopathic injuries are generally not compensable. The Ohio Supreme Court defines the term, “idiopathic,” in the context of on-the-job injuries as “an employee's pre-existing physical weakness or disease which contributes to the accident.” Waller v. Mayfield, 37 Ohio St.3d 118, 524 N.E.2d 458 (1988). Essentially, an idiopathic injury is one that was caused by some circumstances personal to the particular employee rather than caused by any risk associated with the employment. Perhaps the most common example of an idiopathic injury would be an employee getting hurt due to a fainting episode or a seizure at work. If an otherwise idiopathic injury is somehow worsened by a risk or hazard of the employment, however, it is still compensable; so, if an employee suffers a seizure at work but then hits their head on some piece of work equipment during their fall, the employer may not be able to avail themselves of the idiopathic injury defense.
Like many other areas of workers’ compensation law, whether an injury is due to an idiopathic cause and whether the employment worsened the injury are fact-specific inquiries. Moreover, in some cases, there is no apparent or even alleged explanation for how the injury happened whatsoever. In cases of unexplained falls, in particular, the burden shifts to the employee to eliminate idiopathic causes for the fall in order to establish the compensability of their claim.
In sum, even in Ohio’s no-fault workers’ compensation system, employers are not always fully defenseless when it comes to unexplained injuries. Careful accident investigation and review of the medical evidence can sometimes reveal idiopathic causes for previously unexplained accidents and provide a defense against the claim. And even in cases of fully unexplained employee falls, employers can take advantage of the burden shift and force the employee to eliminate possible idiopathic causes of their injuries.