Illinois: Claimant’s Self-Treatment of Foot Blister Does Not Break Chain of Causation

A claimant’s self-treatment in the form of lancing a blister on his foot with a sterilized needle was not an independent intervening act that would break the chain of causation between the work-related blister and a subsequent infection, held an Illinois appellate court, reversing a finding by the state’s Commission. The court utilized a “but-for” analysis, noting that the infection would not have occurred except for the existence of the blister. An IME testified that there was a causal connection between the claimant’s foot condition and the nature of claimant’s work. Claimant drove a truck and repeatedly had to engage a clutch pedal. The infection was a natural consequence of his injury.

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is the co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance.

See Dunteman v. Illinois Workers’ Comp. Comm’n, 2016 IL App (4th) 150543WC, 2016 Ill. App. LEXIS 254 (Apr. 29, 2016)

See generally Larson’s Workers’ Compensation Law, § 10.09.

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law.

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