Lancaster v. Gilbert Development
736 P.2d 237 (Utah 1987)

Facts:
P w/ preexisting conditions has heart attack on job. Files WC.

Issue:
Whether heart attack is the result of an injury by accident arising out of or in the course of his employment.

Held:
NO WC.

Rule: For heart attacks, WC requires proof that 1) an injury occurred by accident and proof of 2) a causal connection between the accident and the activities or exertions required in the workplace.

  • Causation has two requirements:
    1. Legal cause test: A claimant with a preexisting condition must show that the employment contributed something substantial to increase the risk he already faced in everyday life because of his condition.
    2. Medical cause test: The claimant must show that the stress, strain or exertion required by his or her occupation led to the resulting injury or disability.