Harris v General Motors Corp., 2009WL 4145233 (Mich App)
The plaintiff in this matter suffered a fatal head injury after falling onto the floor of the men’s bathroom at an iron plant. The cause of death, confirmed by the medical examiner, was blunt force trauma to the back of the head that resulted in skull fractures and internal bleeding. Proofs were submitted by the defendants suggesting that the plaintiff was unconscious when he fell, consistent with a fainting spell due to his previously documented unusually slow heart rate. The plaintiff’s estate produced no evidence suggesting the work environment contributed to the fall (e.g. no slippery substance on the floor, no fumes causing dizziness, etc.) The Court of Appeals reiterated that “an injury of unknown or idiopathic origin is not compensable simply because it occurred while the employee was in the course of employment on the employers premises.”

Key point: noted by the Court, “as a general rule an injury does not arise out of employment where the predominant cause of the harm was attributable to personal factors and the circumstances of the employment did not significantly add to the risk of harm.” This case effectively serves to reinforce the “idiopathic fall” or “level floor” fall rule as articulated in Ledbetter.