The Challenge of Establishing Causal Links in Workers’ Compensation Claims

green_mold_harmful_mold-1024x768A pre-existing illness requiring time off is difficult, especially if one believes the work environment is worsening the condition. However, proving the environment is the cause of the worsening condition is difficult to do. So, how can a pre-existing illness affect a worker’s compensation claim? What happens if you cannot prove a causal link between a work environment and a worsening condition? The following Louisiana Court of Appeals case helps answer these questions. 

Amy Duplechin was a teacher at St. Landry Parish School beginning in 2000. She suffered from a respiratory condition causing several absences from work. After a semester-long sabbatical, Duplechin claimed her condition worsened due to alleged exposure to mold in her classroom. She claimed she found mold on the back of a bookshelf and growth along the air conditioner’s side. 

According to the School Board, the mold was cleaned by Duplechin and the custodial staff, and she was moved to a new classroom. Duplechin claimed the School Board failed to pay indemnity benefits and medical benefits timely and sought payment of penalties and attorney fees. Still, the workers’ compensation judge decided the law favored the School Board. 

In her appeal, Duplechin asserted that the trial court erred in stating she did not prove a causal connection between her condition and the mold exposure, in finding she was not entitled to the benefits, and in finding that she was not entitled to penalties or attorney’s fees.

La. R.S. 23:1031.1(A) states if an employee is disabled because of an occupational disease or is the dependent of an employee who contracted an occupational disease is entitled to compensation in the same way as if an employee received personal injury from an accident due to his employment. Further, an occupational disease is a disease or illness that arises due to conditions custom to a particular occupation where the employee was exposed to the disease (La. R.S. 23:1031.1(B)). The Supreme Court has stated that an occupational disease is one that has a causal link between the disease/illness and the occupation. 

The court decided there was no error in the trial court’s denial of the requested benefits. The court also decided the trial court’s decision was supported by the documents provided by the plaintiff’s doctor. Duplechin failed to show a causal connection between her condition and her mold exposure. The documents Duplechin provided from her doctor, Dr. Santiago, did not show her general condition upon returning to work and the alleged worsening symptoms. According to the court, Dr. Santiago stated she was experiencing a worsening of her condition but never connected it to exposure at work. The appeals court affirmed the trial court’s decision.

Ultimately, this Louisiana Court of Appeals case highlights the inherent difficulties faced by individuals seeking compensation for worsening conditions related to pre-existing illnesses in the workplace. The burden of proof to establish a causal link between the work environment and the deterioration of the condition can be substantial. In the absence of sufficient evidence connecting the exposure to mold with the worsening of her respiratory condition, the court upheld the denial of benefits to Amy Duplechin. This case serves as a reminder of the challenges individuals may encounter when trying to secure compensation for work-related health issues and emphasizes the importance of strong supporting evidence in establishing a causal connection between the workplace environment and the aggravated condition.

Additional Sources: Amy Duplechin v. St. Landry Parish School Board, ET AL.

Written by Berniard Law Firm Writer: Alivia Rose

Additional Berniard Law Firm Article: When do you Need Your Doctor’s Testimony to Win Your Workplace Injury Lawsuit?

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