Sometimes employees get injured at work for reasons unrelated to the work environment. Idiopathic injuries happen because of an employee’s unique circumstances, not because of a risk related to employment. Usually, workers’ compensation is not available to employees who have idiopathic injuries.
In Minnesota, injuries must arise out of the course and scope of employment to be compensable by workers’ compensation. Injuries that would have occurred regardless of whether the employee was at home, travelling, or at work are considered idiopathic. Because they did not “arise out of” employment and in fact had no relationship to whether the injured person was at work, Minnesota generally does not permit compensation for them.
Common idiopathic injuries include:
- Epileptic seizures
- Diabetic low blood sugar emergencies
- Dental pain
- Migraine headaches
- Fainting
Note that all of these injuries or medical conditions could occur whether an employee was at work or not. For example, people can have seizures anywhere, at any time, without warning.
In some specific situations, the work environment could lead to an injury from one of the above-listed medical conditions. If the work environment significantly contributes to the injury because the employee is at a location or doing a task that makes the injury worse or more likely, the employee may be eligible for workers’ compensation. Figuring out whether the injury is compensable can be difficult.
In several Minnesota cases, judges have looked at injuries that seemed to happen out of nowhere, such as a fall on a dry, non-slippery floor and a slip and fall on the stairs. (Dykhoff v. Xcel Energy, Minn. Sup. Ct, Case No. A12-2324 (2013); Kubis v. Community Memorial Hospital Association, Minn. Sup. Ct, Case No. A16-0361 (2017).) These are close questions about possibly idiopathic injuries. Under some circumstances, employees with idiopathic injuries can receive workers’ compensation. For example, if an employer knows that an employee is diabetic but will not allow her to eat during her shift or leave to get food, a court might find that the resulting diabetic emergency arose out of the scope and course of employment. The fact that she could not eat or leave to get food is an “increased risk” that the general public would not have. (Dykhoff v. Xcel Energy, Minn. Sup. Ct, Case No. A12-2324 (2013).)
Do you have questions about whether you are eligible for workers’ compensation? Joe Osterbauer, Esq. and the Osterbauer Law Firm stand up for injured Minnesota workers’ rights. Joe’s 27 years of workers’ compensation experience and his team’s speedy service combine to get clients the results they need. To schedule a free consultation, visit Osterbauer Law Firm online or call Joe’s office at (612) 334-3434.
