In a workers’ compensation claim, the claimant bears the burden of establishing whether a claim is compensable by showing a direct causal relationship between his employment and his work injury. Following an initial work injury, a claimant may develop a subsequent injury. If that occurs, such developments may also be compensable under the “chain of causation doctrine,” so long as the claimant shows a relationship between the new injury and his original work injury. In City of Colorado Springs v. ICAO, the Court of Appeals decided that under the “chain of causation doctrine” it is not necessary to prove that a claimant’s employment conditions directly caused a subsequent injury in order for that subsequent injury to be compensable. Rather, it is sufficient if a claimant shows that the original work injury played a contributing “causative role” in his subsequent injury.
Claimant worked for the City of Colorado Springs (the “City”), maintaining its wastewater management system. In March 2018, at the end of a day’s maintenance rounds, Claimant reached for a work tool with one hand and his laptop with the other. Upon grabbing both items, Claimant’s back popped, resulting in a diagnosis of a strained thorax. In April 2018, Claimant was admitted to the hospital for a gastrointestinal bleed likely caused by medication for his back pain and lower extremity swelling. In May 2018, Claimant was hospitalized again for severe back pain and lower extremity swelling. At that second hospitalization, Claimant was found to have sustained a compression fracture in his thoracic spine, severe destruction of a vertebra, and staph infection in his spinal disk. Following these new diagnoses, Claimant underwent decompression back surgery and subsequently lost use of his legs. In November 2018, Claimant filed for medical and TTD benefits. The City contested this application, claiming that the infection and paraplegia were intervening and unrelated events upon the original work injury and therefore were non-compensable. However, the administrative law judge Administrative Law Judge (“ALJ”) found that the original work injury “created conditions conducive” to the subsequent injuries that resulted in the damage to his spine and awarded medical and temporary total disability benefits. The City appealed.
In affirming the ALJ’s award of benefits, the Court of Appeals (“the Court”) explained the chain of causation doctrine. The Court analyzed a decision made in a prior case, which held the “chain of causation analysis is reserved for cases in which the industrial injury leaves the body in a weakened condition and the weakened condition plays a causative role in the subsequent injury.” To prove that a subsequent injury falls within chain of causation, a claimant must demonstrate it is more probably true than not that a subsequent injury flowed from an original work injury. This is a question of fact for resolution by the ALJ. In this case, the ALJ decided there was substantial evidence that the infection flowed from the original back injury. Under a chain of causation analysis, the Court emphasized that it was not necessary for work conditions to have directly caused a subsequent injury. Instead, it was sufficient that Claimant’s weakened back condition from the original injury played “a causative role” in his resulting infection and paraplegia. The Court found there was substantial evidence to support this finding and affirmed the ALJ’s decision.
City of Colorado Springs. v. ICAO, No. 19CA1795 (Colo. App. July 9, 2020)
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