Understanding Work-Related Death Claims in Missouri.
When an employee dies at work, it is a tragic situation. Often, an employee’s death leads to complex legal questions for families and employers alike related to death benefits. Sometimes idiopathic medical conditions with no clear external cause are involved, and families must navigate strict statutory requirements, evolving case law, and issues establishing causation.
Idiopathic Conditions Explained
Idiopathic conditions are health conditions that occur spontaneously or without a known cause, such as a seizures, stroke, or heart attack. These conditions can surface at any time and raise complex issues of causation, especially if an employee dies suddenly and without any witnesses to the accident.
In Missouri, injuries that result directly or indirectly from idiopathic causes are not compensable unless the workplace incident was the prevailing factor. Courts rely on causation to determine whether an injury is compensable, so it is critical to determine if an idiopathic condition was involved and document any workplace hazards that the employee was exposed to.
Missouri courts emphasize that the idiopathic condition must be the primary cause of death to deny workers’ compensation benefits coverage. In other words, if the idiopathic condition simply contributed but the workplace hazard was the primary cause, then a death claim can still be compensable. If the death was a purely personal medical event and workplace hazards added no risk, compensation is often denied.
This approach is emphasized in Halsey v. Townsend Tree Service, in which the appellate court analyzed an idiopathic condition within a workers’ compensation death benefits claim. In that case, a worker died from fatal heatstroke and while obesity was considered an idiopathic condition, the court found that the obesity contributed but did not exclusively cause the death.
Equal Exposure in Missouri Workers’ Compensation
Missouri courts also apply an equal exposure test to determine if the death arose out of employment. Under this doctrine, an injury is not compensable if the employee was exposed to the same hazard outside of work. The seminal cases that define the discuss the exposure analysis are Miller v. Missouri Highway and Transportation Commission and Johme v. St. John’s Mercy Healthcare.
In Miller v. Missouri Highway and Transportation Commission, the claimant alleged injury from walking on a flat surface at work. The Missouri Supreme Court reasoned that walking on level ground is a risk encountered equally in everyday life, thus the hazard did not arise out of employment. The court emphasized that workers’ compensation does not cover hazards that are common to all environments unless employment conditions increase the risk.
Similarly, in Johme v. St. John’s Mercy Healthcare, the claimant twisted her ankle while turning to get coffee in a break room. The court denied benefits, finding that the risk of turning and walking was not unique to employment. This decision further clarified that for an injury to be compensable, the job must create or increase the risk and not simply be the setting.
These cases emphasize the importance of consulting with an experienced workers’ compensation attorney to determine if your loved one was exposed to a unique risk or condition of their employment.
The “Found Dead” Presumption
One of the most challenging aspects to a workers’ compensation death claim is causation, especially when there are no witnesses. Missouri, however, recognizes the “found dead” presumption, which can help survivors file a submissible claim for benefits. The doctrine presumes that an employe that is found dead at a time and place of employment suffered an injury arising out of and in the course and scope of employment. However, this doctrine is not automatic and has limits. Missouri courts require more proof than simply being present at work; there must be credible circumstances to support compensability and requires medical evidence, proof of employment, premises evaluation, and unique risk evidence.
The “found dead” presumption does not invalidate idiopathic exclusions, rather it helps prove an accident when it can be reasonably inferred. Claimants must still demonstrate that a workplace hazard, not just a personal medical event, was the primary cause of death.
How to build a claim when no one witnessed the accident
Missouri courts require more proof than simply being present at work; there must be credible circumstances to support compensability and that requires medical evidence, proof of employment, premises evaluation, and unique risk exposure analysis. Our attorneys are well-versed in workers’ compensation death claims and understand the critical importance of a thorough investigation including:
- Documenting location, body position, nearby equipment, heights, edges, or other environmental factors (heat index, ventilation, chemical exposure) and signs of traumatic event (blood, bruising, cuts).
- Seeking expert medical opinions on whether workplace factors could be the prevailing factor in the fatal outcome versus an idiopathic cause.
- Establishing that the decedent was on the clock or within the course and scope of employment, including on accidents on premise or under travel status.
- Documenting how workplace conditions differ from everyday life such as elevation, machinery, furniture, or special duties that increase risk.
Workers’ Compensation Death Benefits Available in Missouri
When a work-related death occurs, the employer or insurance carrier must report the death to the Divisions of Workers’ Compensation within 30 days, and the Division will notify dependents of their rights. When are injury or death is compensable, surviving dependents can receive weekly benefits equal to 66 2/3% of the worker’s average weekly wage for the year immediately preceding the fatal accidents, subject to certain caps, and funeral expenses up to $5,000.
Bottom Line
Missouri law is clear: idiopathic causes alone do not justify death benefits under workers’ compensation. However, when workplace conditions are the prevailing factor or can be reasonable inferred under the “found dead” presumption, survivors may qualify for death benefits. These cases turn on details, evidence, and expert legal analysis.
If your family is dealing with a work-related death, contact Bollwerk & Associates today for a free consultation.