Worker's prior drug use, psychiatric history are relevant to comp claim
Case name: Clark v. Cry Baby Foods, LLC, No. 40016 (Idaho 08/14/13).
Ruling: The Idaho Supreme Court held that a worker was entitled to temporary disability benefits and permanent partial disability benefits.
What it means: In Idaho, all medical information relevant to a particular injury must be provided to the employer.
Summary: A worker at an onion processing plant was injured when his right forearm was caught in a machine. He sustained significant soft tissue damage. Later, he was diagnosed with post-traumatic stress disorder resulting from the accident. The worker had a history of substance abuse, a mood disorder, seizures, and a personality disorder. The worker had surgery on his arm but continued to complain of pain and reduced strength in his hand and arm. The worker was awarded temporary disability benefits and permanent partial disability benefits. He asserted that his medical records were fraudulently obtained and that the records were not relevant to his work injury. The Idaho Supreme Court rejected the worker's arguments and affirmed the award of benefits.
The court found that the worker agreed to the release of his medical information. There was no indication that his medical releases were deficient.
The court also found that the worker's medical history was relevant to the proceedings. The court explained that all medical information relevant to a particular injury must be provided to the employer. The records were necessary to determine the extent the current injury was responsible for the worker's injury.
Although the worker objected to the consideration of his prior drug use, psychiatric history, and prior injuries, he sought disability benefits based on physical and psychological impairments. The court explained that it was necessary to determine if he was previously disabled. The court noted that multiple health professionals opined that a portion of the worker's psychological impairment was related to an underlying personality disorder and history of substance abuse. Also, he previously filed a workers' compensation claim related to an injury on the same arm.
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November 4, 2013
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