Michigan Workers' Comp Defense Blog

Why Some Workplace Falls Are Not Compensable: The Idiopathic Fall Doctrine Explained

Under Michigan workers’ compensation law, compensation benefits are payable to an employee who sustains a personal injury that “arises out of” and “in the course of employment.” “Arises out of” and “in the course of” are two distinct legal requirements. And an injury that happens at work does not necessarily mean that it arose out of the work. An example of this are idiopathic fall cases, which often fall outside the scope of compensable claims.

What is an Idiopathic Fall?

An idiopathic fall is a fall that results from some disease or infirmity that is strictly personal to the employee and unrelated to their employment.

The term “idiopathic” can be a bit misleading, as it technically means “of unknown cause.” However, workers’ compensation case law refers to any fall that is caused by a health issue that is strictly personal to the employee as an “idiopathic” fall. See McClain v Chrysler Corp, 138 Mich App 723 (1984). Examples of health issues that are strictly personal to the employee include seizures, fainting spells, and symptoms from a chronic illness.

The Workers’ Disability Compensation Appeals Commission recently decided Eileen Howell v. Stapleton’s Corner Market, 2025 ACO#3, in which it discusses the topic of idiopathic falls at length.

Eileen Howell v. Stapleton’s Corner Market

In this case, Ms. Howell worked at a Subway counter inside a grocery store. One day, after a busy shift, she felt dizzy and overheated. She sat down briefly, stood up to help a customer – and fainted. She hit her head on the floor and was diagnosed with a traumatic brain injury.

Ms. Howell had a medical history of hypothyroidism – a personal condition that can cause low blood pressure and fainting spells especially when standing suddenly. And the Commission noted that Ms. Howell had not been taking her thyroid medication.

The Appeals Commission ruled that Ms. Howell’s fall was the result of her untreated hypothyroidism. They found that:

• Her job did not aggravate the condition;
• The act of standing up was a normal, everyday activity – not a work specific-risk;
• And the workplace did not increase the risk of the injury.

Ultimately, the Commission ruled that Ms. Howell’s fall was idiopathic, and therefore not compensable under the Act.

Why it matters?

For an injury to be compensable, it is not enough that the injury happened at work. The injury must also arise out the employment – meaning there has to be a connection between the job and what caused the injury or made it worse. If the workplace increased the danger – (i.e. someone faints while working on a ladder and, thus, falls from a great height) that could turn an idiopathic fall into a compensable claim. But if the same person fainted while standing on level ground – it is likely a strictly personal condition and not compensable.

These are very fact-dependent situations. If you have any questions evaluating whether an alleged work injury is idiopathic or compensable, please contact one of our workers’ compensation attorneys.

Categories: Case Law Updates, Compliance, Liability, Safety, Workers' Compensation