Jane suffers from diabetes, which is well regulated most of the time. Every so often, however, she’ll suffer a fleeting bout of hypoglycemia. When this happens, she experiences lightheadedness and dizziness. One day at work, Jane was taking inventory down from a shelf when she began to experience these symptoms. As a result, she lost her balance and fell from the step stool on which she was standing. She threw her arms out to break her fall and wound up suffering a nasty wrist fracture requiring surgery. Several days later, Jane was giving a recorded statement to the workers’ comp claims adjuster. She told the adjuster her diabetes made her dizzy and she fell. The adjuster responded to Jane’s honesty by denying her claim for benefits because, “We’re not responsible for your diabetes.” Was the adjuster right?
Not entirely. While it’s true the insurance company is not responsible for Jane’s diabetes, it is responsible for the fractured wrist, medical bills, and lost wages resulting from the fall that her diabetes caused. This is so because the facts of Jane’s case trigger the ‘idiopathic fall’ doctrine. An idiopathic fall is one whose cause is related to some pre-existing medical condition rather than an actual work-related cause. However, when the conditions of the employment increase the dangerous effects of such a fall (such as working at heights), the resulting injuries are compensable. Think of it this way - - if Jane’s job duties required her to be seated behind a desk all day, her bout of hypoglycemia would most likely have resulted in no injuries. But because her duties required her to be standing atop a step stool at the time she was stricken, Jane’s fall resulted in severe injuries. Jane’s dizziness may not have been caused by the conditions of her work, but her injuries were.