Ohio: Idiopathic Injury Not Compensable Where Employment Conditions Did Not Increase Danger

An Ohio nurse, who sustained injuries in a bizarre auto accident as she traveled to the residence of one of her clients, did not sustain an accidental injury arising out of her employment where she indicated she had stopped at a stop light and the next thing she remembered was waking up after hitting a utility pole along the side of the street. The appellate court acknowledged that an idiopathic injury was compensable if the employment significantly contributed to the injury by placing the employee in a position that increased the dangerous effects of the accident. It agreed with the trial court that the light pole was entirely unrelated to the nurse’s employment and noted that she could have sustained the same injuries to her leg if she suffered the syncopal episode while she was walking, rather than driving.

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 Miller v. Horizons Health Servs., L.L.C., 2017-Ohio–465, 2017 Ohio App. LEXIS 460 (Feb. 9, 2017)

See generally Larson’s Workers’ Compensation Law, § 7.04.

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