## Facts

- James Barron worked in construction as a welder/connector of structural iron.
- While working on the second story of a building, Barron walked on temporary metal decking over steel beams to cut a floor drain opening and managed a cutting-torch hose.
- Barron could not tie off his safety harness while moving across the work area and walked backward to keep the hose from kinking.
- Barron stepped off an unguarded edge, fell more than fourteen feet to a concrete floor, and suffered serious injuries.
- A urine sample taken the same day tested positive for cocaine metabolites above the applicable screening and confirmatory thresholds.
- Barron admitted using cocaine two days before the accident.
- Barron sought workers’ compensation benefits, including permanent partial disability; the employer and carrier contested disability compensation based on the statutory presumption tied to illegal drug presence, while conceding the claim was otherwise compensable.
- At the administrative hearing, Barron presented testimony from coworkers and medical personnel that he showed no signs of impairment and was alert and oriented, and he relied on evidence of unsafe working conditions as an alternative cause of the fall.

## Issues

1. Whether the claimant presented sufficient evidence to rebut the statutory presumption that illegal drug use was the major contributing cause of the workplace injury.
2. Whether the Labor Commission’s conclusion that the presumption was not rebutted was supported by substantial evidence, given the record evidence of non-impairment and alternative causation.

## Decision

- The Utah Court of Appeals set aside the Labor Commission’s order denying disability compensation and remanded for reconsideration.
- The court held the Commission failed to meaningfully evaluate rebuttal evidence and applied the presumption in a way that functionally treated it as conclusive.
- The court directed the Commission to reconsider the claim under a correct understanding of “major contributing cause” and to address the evidence bearing on impairment and workplace conditions.

## Legal Principles

- A statutory presumption that illegal drug use was the major contributing cause of an injury is rebuttable; it does not automatically bar disability benefits.
- “Major contributing cause” requires more than showing drug presence; drug use must be the primary or predominant cause relative to other contributing factors.
- In applying a rebuttable presumption, the agency must evaluate all material rebuttal evidence, including testimony of non-impairment and evidence of alternative causes.
- Substantial-evidence review requires a reasoned decision that addresses important contrary evidence; ignoring such evidence can require the decision to be set aside and remanded.

## Conclusion

The court required the Labor Commission to re-evaluate whether Barron rebutted the drug-use presumption by considering record evidence that he appeared unimpaired and that unsafe work conditions could explain the fall, because the Commission’s prior denial did not adequately analyze that evidence under the statutory “major contributing cause” standard.


Barron v. Labor Comm’n, 274 P.3d 1016 (Utah Ct. App. 2012)