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Stressing that “idiopathic” and “unexplained” were not synonymous, an Arkansas appellate court agreed with an ALJ’s decision denying workers’ compensation benefits to a worker who, after experiencing severe gastrointestinal pain at his employer’s premises, went to a company rest room, fainted, and struck his knee and head on a bathroom fixture. The worker contended that on the day before his injury, he had noticed blood in his stool at home after a particularly strenuous workday. The following morning, he went to the employer’s premises in order to complete workers’ compensation claims forms. While there, he again felt ill and went to the rest room, where he fainted. The court stressed that the worker’s GI bleed was idiopathic—none of the worker’s treating physicians attributed the bleeding to work-related activity. His injuries were caused by that idiopathic condition, and not by a risk at work.
Thomas A. Robinson, J.D., the co-Editor-in-Chief and Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law(LexisNexis).
LexisNexis Online Subscribers: Citations below link to Lexis Advance.
See Nolen v. Walmart Assocs., 2021 Ark. App. 68 (Feb. 10, 2021)
See generally Larson’s Workers’ Compensation Law, § 9.01.
Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law
For a more detailed discussion of the case, see
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