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					<title>Why Some Workplace Falls Are Not Compensable | Idiopathic Fall Doctrine
Explained | Foster Swift</title>
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				<title>Why Some Workplace Falls Are Not Compensable: The Idiopathic Fall Doctrine
Explained</title>
				<dc:creator>Michael A. Cassar, Brian G. Goodenough, Dina D. Kashat, Samantha D. Shepard</dc:creator>
<guid isPermaLink='false'>blogpost-some-workplace-falls-not-compensable-idiopathic-fall-doctrine</guid>

					<pubDate>Wed, 30 Apr 2025 09:00:01 -0400</pubDate>
					<content:encoded><![CDATA[<p><img src="https://www.miworkcompdefenseblog.com/assets/htmlimages/Fainting%20Cropped.jpg" width="300" height="244" alt="Man kneeling down to help other man who fainted" style="float: left; margin-right: 5px; margin-top: 5px;" />Under Michigan workers&rsquo; compensation law, compensation benefits are payable to an employee who sustains a personal injury that &ldquo;arises out of&rdquo; and &ldquo;in the course of employment.&rdquo; &ldquo;Arises out of&rdquo; and &ldquo;in the course of&rdquo; are two distinct legal requirements. And an injury that happens at work does not necessarily mean that it <em>arose out of the work</em>. An example of this are idiopathic fall cases, which often fall outside the scope of compensable claims.</p>
<p><strong>What is an Idiopathic Fall?</strong></p>
<p>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.</p>
<p>The term &ldquo;idiopathic&rdquo; can be a bit misleading, as it technically means &ldquo;of unknown cause.&rdquo; However, workers&rsquo; compensation case law refers to any fall that is caused by a health issue that is strictly personal to the employee as an &ldquo;idiopathic&rdquo; fall. See <em>McClain v Chrysler Corp</em>, 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.</p>
<p>The Workers&rsquo; Disability Compensation Appeals Commission recently decided <em>Eileen Howell v. Stapleton&rsquo;s Corner Market</em>, <a href="https://adms.apps.lara.state.mi.us/AppellateCommission/ViewWCACDecisionDocument/6668">2025 ACO#3</a>, in which it discusses the topic of idiopathic falls at length.</p>
<p><strong>Eileen Howell v. Stapleton&rsquo;s Corner Market</strong></p>
<p>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 &ndash; and fainted. She hit her head on the floor and was diagnosed with a traumatic brain injury.</p>
<p>Ms. Howell had a medical history of hypothyroidism &ndash; 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.</p>
<p>The Appeals Commission ruled that Ms. Howell&rsquo;s fall was the result of her untreated hypothyroidism. They found that:</p>
<ul>
<li>Her job did not aggravate the condition;</li>
<li>The act of standing up was a normal, everyday activity &ndash; not a work specific-risk;</li>
<li>And the workplace did not increase the risk of the injury.</li>
</ul>
<p>Ultimately, the Commission ruled that Ms. Howell&rsquo;s fall was idiopathic, and therefore not compensable under the Act.</p>
<p><strong>Why it matters?</strong></p>
<p>For an injury to be compensable, it is not enough that the injury happened at work. The injury must also arise out the employment &ndash; 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 &ndash; (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 &ndash; it is likely a strictly personal condition and not compensable.</p>
<p>These are very fact-dependent situations. If you have any questions evaluating whether an alleged work injury is idiopathic or compensable, <a target="_blank" title="WC Practice Page" rel="noopener" href="https://www.fosterswift.com/services-Workers-Compensation-Defense-litigation.html">please contact one of our workers&rsquo; compensation attorneys.</a></p>]]></content:encoded>
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