by Jennifer M. Smith, Esq.

Unraveling what constitutes an “idiopathic” injury and determining whether these particular claims are compensable can be tricky and a recent Court of Appeals decision demonstrates the very fine line in making this determination. An idiopathic injury is one in which the cause is a physical or mental condition personal to the employee (in other words, the employee would be equally exposed to a risk of that injury independent of the work place). As a general rule, idiopathic injuries are not compensable under the Georgia Workers’ Compensation Act since they do not arise out of the individual’s employment even if they occur while the individual is at work, unless the work environment increases the individual’s risk of injury.

In the new case, the employee was seated at her desk when she rose from her chair and heard a “pop” in her left knee. The Court of Appeals determined that the injury was not compensable because there was no causal connection between her employment and her injury, since she was not exposed to any particular risk unique to her employment when she rose from the chair. The Court pointed out that the employee did not get up from her chair in an unusual manner, there was no unique configuration of her desk or chair that caused her to lose her balance, there was no work-related emergency which caused her to jump from her chair in a hurried manner, and she did not come into contact with any other object or hazard (such as a desk, stairs, or piece of equipment). If any of these scenarios had occurred, the Court may have ruled differently, determining that the work environment had increased her risk of injury. Two judges dissented from the decision, however, and pointed out that the injured employee only rose from her desk because her supervisor asked her to get up in order for him to complete some paperwork. The dissent argued that one of the injured employee’s job duties was to carry out the instructions of her supervisor and therefore she immediately stood up from the desk only because he asked her to move. Because the supervisor expressly directed her to undertake a specific physical activity (getting up) and because she was injured while doing so, the dissent argued there was a sufficient causal connection between the conditions of employment and the resulting injury to make the claim compensable.

As this case demonstrates, figuring out whether what appears to be an idiopathic injury is actually compensable is fact specific and the details very much matter. Idiopathic injuries will be one of the topics covered at this year’s Workers’ Compensation Law Institute in October and undoubtedly this case will be part of the discussion. We will provide an update following the seminar with any further insights regarding the sometimes confusing and fact specific topic of idiopathic injuries.