Clements
Conn.Jun 24, 2021
The plaintiff appealed from the decision of the Compensation Review Board, which affirmed the decision of the Workers' Compensation Commis- sioner dismissing the plaintiff's claim for certain disability benefits. While working for the defendant employer, the plaintiff, who had a history of cardiac disease, among other conditions, and who was stand- ing on a level surface, became lightheaded, passed out, fell backward, and hit her head on the ground. The plaintiff was then taken to a hospital, where she suffered cardiac arrest and was treated for her cardiac episode and head trauma. In denying the plaintiff's claim for benefits, the commis- sioner determined that the plaintiff's head injury did not arise out of her employment but, rather, was caused by her cardiac condition, and, therefore, was not a compensable injury. After the board upheld the commissioner's decision, the plaintiff appealed to the Appellate Court, which reversed the board's decision and remanded the case with direc- tion to sustain the plaintiff's appeal. In doing so, the Appellate Court relied on this court's decision in Savage v. St. Aeden's Church (122 Conn. 343), in which this court concluded that a head injury sustained by an employee at his or her workplace due to a fall caused by the employee's purely personal medical condition, i.e., an idiopathic fall, was per se compensable. On the granting of certification, the defendant employer and the defendant insurer appealed from the Appellate Court's judgment to this court. Held that this court overruled its decision in Savage to the extent that it held that an idiopathic fall on a level surface occurring during the course of employment is compensable as a matter of law, and, accordingly, this court reversed the Appellate Court's judgment with direction to affirm the board's decision upholding the commission- er's denial of the plaintiff's claim for benefits: because Savage was predicated on a misapplication of prior precedent and out of step wit