North Carolina employers have generally not been held liable for injuries arising solely from an employee’s idiopathic conditions that do not arise from the worker’s employment. However, if the injury is also in part related to the risks presented by the employment, the injury is typically compensable. This has raised the question for many employers of how this applies to employment that requires driving. Luckily multiple court cases have provided an answer to this question.
First of all, case law defines idiopathic conditions as one that arises spontaneously from a particular employee’s mental or physical condition. Examples of this could be an employee’s unknown infirmities such as a leg suddenly giving out or conditions such as epilepsy, diabetes, or heart disease. On its own, injuries from these conditions in the workplace will not be compensable in most cases. However, if dangers in the workplace such as heavy machinery contribute, they generally will be.
Employment that requires driving raises a unique question, what if an idiopathic condition causes a motor vehicle accident? An obvious defense for these claims would be that the injury could have happened when the employee was driving, whether they were at work or not. But, on the other hand, the plaintiff’s counsel can easily argue that for employment that requires driving, the hazards of driving are an inherent risk of the job. Fortunately, case law has provided us with an example of these arguments in play and how courts have interpreted them.
In a previous case before the North Carolina Court of Appeals, a plaintiff worked for a home health care provider and was required to drive between multiple patients every day. During one of these shifts, the employee blacked out and crashed into the side of a building. The employee sued their employer, and the court found that the job’s travel requirement inherently exposed the plaintiff to the risk thereof.
Another case before the state’s Court of Appeals resulted in a similar ruling. In this case, the employee suffered a blackout whilst driving the employer’s truck. This resulted in the vehicle running off the road, striking a lamppost, and then tipping over. The court found again in this case that the employee’s duties inherently involved travel and that the risks of the travel are the risks of the employment. As a result, the claim was compensable.
This appears to make a clear standard that in North Carolina, if a job inherently involves regular travel, they are also exposed to the risk of a motor vehicle accident, and when an idiopathic condition results in an accident, it is, therefore, likely compensable.