Officer's oxycodone overdose doesn't secure benefits for widow
Case name: Sapko v. Connecticut, et al., No. SC 18680 (Conn. 06/12/12).
Ruling: The Connecticut Supreme Court held that a widow was not entitled to benefits for an officer's death caused by an overdose of prescription medications.
What it means: In Connecticut, the direct and natural consequence rule should be utilized in analyzing the causation in cases involving a subsequent injury or an aggravation of an earlier, primary injury.
Summary: A corrections officer for the state experienced compensable work-related back injuries. He was prescribed various medications for back pain, including oxycodone. He previously had treatment with a psychiatrist for depression. After his back injuries, he complained to the psychiatrist of depression and racing thoughts. The psychiatrist prescribed the antipsychotic medication Seroquel. One week later, the officer died. At the time of his death, his level of oxycodone was 20 times higher than the therapeutic dosage, and his level of Seroquel was five times the therapeutic dosage. The officer's widow sought death benefits. The Connecticut Supreme Court held that she was not entitled to death benefits.
The court agreed with the workers' compensation commissioner's finding that the officer's ingestion of excessive quantities of his prescription medications broke the chain of causation between his compensable work injuries and his death. A medical expert stated that the elevated level of oxycodone likely would not have been fatal if the officer had not simultaneously overdosed on Seroquel. There was evidence supporting a finding that the officer's treatment for his back injury and depression were unrelated, and the two drugs could be taken together safely.
Also, the officer received instructions and counseling regarding the proper use of controlled substances for pain control and entered into a controlled substance agreement as part of his treatment plan. There was no evidence that the officer experienced confusion as a side effect of the oxycodone that caused him to overdose or that the medication was ineffective and he overmedicated to obtain relief.
The court said it was reasonable for the commissioner to conclude that the causal link between the officer's death and his compensable injuries were too tenuous to support a finding of causation.
Read more at the WorkersComp Forum homepage.
July 30, 2012
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