Quast v. Utah Labor CommissionAnnotate this Case
The Supreme Court reversed the judgment of the court of appeals, which set aside the order of the Labor Commission concluding that Respondent had failed to make out a permanent total disability claim against her former employer, the University of Utah Huntsman Cancer Hospital. The Commission reversed the order of an administrative law judge (ALJ), which awarded Respondent permanent total disability benefits. In denying Respondent’s application for permanent total disability benefits, the Commission concluded that Respondent had failed to show that she was limited in her ability to do basic work activities. The court of appeals reversed, concluding that Respondent was not limited in her ability to perform basic work activities because her impairments did not “reasonably” limit her. The Supreme Court disagreed and affirmed the Commission’s order denying Respondent’s application for permanent total disability benefits, holding (1) both the court of appeals and the Commission misstated the burden of proof on the “other work reasonably available” element of a permanent total disability claim; and (2) the court of appeals erred in reversing the Commission’s determination that Respondent was limited in her ability to do basic work activities.