City of Brighton v. Rodriguez
Colorado Supreme Court
318 P.3d 496 (2014)
Helen Rodriguez (plaintiff) worked as a special-events coordinator for the City of Brighton (defendant). Her office was in the basement of city hall. One day, Rodriguez suddenly fell down a flight of concrete stairs on the way back to her office after a chat with Scott Miller and Dennis Williams, her coworkers. The stairs were dry and clear prior to the fall. Rodriguez had not been ill or dizzy before the fall. Miller and Williams both testified that the cause of Rodriguez’s fall was not apparent and that she had been speaking and acting normally just before the fall. When she was taken to the hospital, medical providers discovered that Rodriguez had four unruptured aneurysms in her brain. However, three doctors testified at Rodriguez’s workers’-compensation hearing, and two of the three doctors opined that the aneurysms did not cause Rodriguez’s fall; the other doctor suggested that the fall was caused by the aneurysms. The administrative law judge (ALJ) credited the two doctors who agreed regarding the aneurysms. The ALJ determined that the cause of the fall was unexplained, so Rodriguez’s injuries were not covered by workers’ compensation because she failed to show a causal connection between her injury and her employment. The industrial-claims appeals office affirmed. The court of appeals set aside the appeals-office order, finding that uncertainty as to causation cannot bar a workers’-compensation claim. The city appealed.
Rule of Law
Holding and Reasoning (Rice, C.J.)
Dissent (Eid, J.)
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