JBS Carriers v. HickeyAnnotate this Case
The Supreme Court reversed the determination of the court of appeals that Claimant's long drive in a commercial truck was not an unusual or extraordinary activity in comparison to the ordinary activities people perform in their nonworking, everyday lives and vacated the conclusion that there was substantial evidence to support the ALJ's finding that Claimant's "super obesity" was a preexisting condition, holding that Claimant was entitled to benefits.
At the end of a three-day drive from Utah to California, Claimant was diagnosed with a blood clot in his left leg, which caused blood clots in his lungs. Claimant could not return to work and sought workers' compensation. Employer disputed the claim, arguing that his injuries were caused by his "super obesity" and that super obesity should be considered a preexisting condition under the circumstances. The ALJ granted benefits, concluding that Claimant had satisfied the Allen v. Industrial Comm'n, 729. P.2d 15 (Utah 1986), test for legal causation. The Labor Commission Appeals Board reversed, concluding that Claimant's work activities were not unusual or extraordinary under Allen. The Supreme Court reversed, holding (1) Claimant's drive to California was an unusual activity; and (2) therefore, Claimant showed legal causation.