Prescription drug overdose bars widow's claim

In Ohio, the "chain of causation" approach is used to determine whether suicide was a proximate result of a work-related injury and therefore an exception to the rule that suicides are not compensable. However, Ohio courts have declined to extend the chain of causation approach to include accidental deaths caused by drug abuse.

Case name: Parker v. Honda of America Mfg., et al., No. 14-09-27 (Ohio Ct. App. 12/28/09).

Ruling: The Ohio Court of Appeals affirmed the finding that a widow was barred from claiming death benefits for her husband's accidental drug overdose.

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What it means: In Ohio, the "chain of causation" approach is used to determine whether suicide was a proximate result of a work-related injury and therefore an exception to the rule that suicides are not compensable. However, Ohio courts have declined to extend the chain of causation approach to include accidental deaths caused by drug abuse.

Summary: A Honda employee injured his back at work. He was prescribed a strong narcotic pain medication and became addicted. He was found dead with a syringe in his arm, a lighter and spoon, and prescription and illegal drugs. The cause of death was a lethal concentration of the prescription drug. His widow filed a complaint arguing that his death was a result of a prescription drug overdose which was the direct and proximate result of his work injury. She argued that the chain of causation approach should be applied to her husband's death. Under this approach, a worker's death is compensable if his work-related injury caused him to "become dominated by a disturbance of the mind of such severity as to override normal rational judgment."

The Court of Appeals rejected her arguments. It pointed out that the chain of causation approach only applied to cases involving suicide. It further explained that although courts have allowed benefits to be extended for medical conditions that had a proximate link to the original work-related injury, the courts had not permitted the further linking of injuries caused by that condition. It therefore refused to expand the exception to include her husband's accidental death from a drug overdose and affirmed the denial of benefits.

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February 4, 2010

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