West Virginia Employee’s Unexplained Fall Was Idiopathic And Not Compensable

In a memorandum decision, the Supreme Court of Appeals of West Virginia affirmed the denial of workers’ compensation benefits to an employee who suffered a dislocation of his left knee and a tear of the meniscal cartilage while at work, finding that the injury was idiopathic in nature and not the result of any condition in the employment [Price v. Kingsford Mfg. Co., 2015 W. Va. LEXIS 245 (Apr. 6, 2015)]. All the testimony indicated that the employee was walking when he suddenly fell to the concrete floor. No one could identify any place where the employee slipped or tripped. He was not carrying any work materials at the time of the fall. The Office of Judges determined that the injury occurred while the employee was merely walking across the floor and his left knee gave out. This caused him to fall to the floor. The Board adopted the findings. The state high court also affirmed. While the injury occurred at work, it was in no way a result of the employee’s work. Since the injury was idiopathic in nature it was not error to reject the claim.

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