Lancaster v. Gilbert Development

James Lancaster (plaintiff) was a 43-year-old worker at Brian Head Ski Resort (the resort), located at 10,000 feet above sea level. On February 17, 1984, Lancaster suffered a heart attack while clearing snow with a backhoe at the resort. Lancaster was at a higher risk of heart attacks because he had smoked for 20 years and had high cholesterol, elevated uric acid, and borderline diabetes. Lancaster sought workers’-compensation benefits for his heart attack. In proceedings before an administrative-law judge (ALJ) at the State Industrial Commission (defendant), Lancaster’s physician testified that the high altitude, cold weather, and conditions under which Lancaster was clearing the snow probably precipitated Lancaster’s heart attack. However, a cardiologist testified that although Lancaster’s physical history placed him at a higher risk of developing coronary artery disease than other men his age, the cardiologist did not consider Lancaster’s work to be a risk factor for a heart attack. The cardiologist further testified that he would guess that Lancaster’s heart attack was 90 percent attributable to Lancaster’s preexisting conditions and 10 percent attributable to Lancaster’s work conditions. A doctor for Utah’s State Insurance Fund (defendant) testified that Lancaster’s heart attack was not due to his working conditions. The doctor said that Lancaster’s heart attack was instead the normal progression of coronary artery disease exacerbated by Lancaster’s other conditions. The ALJ denied Lancaster’s claim, finding that Lancaster had not shown that his heart attack was an injury by accident that was caused by Lancaster’s exertion during work. Lancaster sought review from the Utah Supreme Court.