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

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

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


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.