What constitutes unusual or extraordinary work activity for workers' compensation claims with preexisting conditions? White v. Labor Commission Explained

The Utah Court of Appeals recently addressed the heightened legal causation standard that applies to workers’ compensation claims when an employee has a preexisting condition that contributes to a workplace injury in White v. Labor Commission.

Background and Facts

Shawn White sustained a left knee injury while working for Golden Empire Manufacturing. While inspecting and measuring a steel beam, White walked backwards while maintaining tension on a measuring tape. His right leg hit a six-inch-tall block of wood, causing him to shift his weight to his left knee, resulting in a twisting and grinding motion. A medical panel determined that White had chronic degenerative joint disease in his left knee prior to the accident, which the work incident likely aggravated.

Key Legal Issues

The primary issue was whether White’s work activity satisfied the heightened legal causation standard that applies when a preexisting condition contributes to a workplace injury. Under Allen v. Industrial Commission, the employee must prove that “the employment contributed something substantial to increase the risk he already faced in everyday life because of his preexisting condition.”

Court’s Analysis and Holding

The court applied the two-step analysis from Murray v. Labor Commission: first, characterizing the employment-related activity considering the totality of circumstances, and second, determining whether the activity was objectively unusual or extraordinary compared to everyday life activities. The court concluded that walking backwards while focused on a task, stumbling on an object, and shifting weight to avoid falling are activities “generally expected of people in today’s society.” The court compared White’s situation to common activities like home improvement projects or navigating narrow aisles while traveling with luggage.

Practice Implications

This decision reinforces that the heightened legal causation standard requires more than showing a workplace accident occurred. Practitioners must demonstrate that the specific work activity involved unusual or extraordinary exertions beyond typical daily activities. The court emphasized that activities involving “jumping, lifting great weight, or repetition” or occurring in “exigent” or “peculiar” circumstances are more likely to satisfy the standard. Simple stumbling and weight-shifting, even in a work context, may not meet this threshold when comparable to activities people encounter in everyday life.