## Facts

- James Lancaster, age 43, worked for Gilbert Development operating a backhoe at a ski resort around 10,000 feet elevation.
- On February 17, 1984, he began his shift at 7:00 a.m. and performed routine snow-clearing using a backhoe with a heated cab and hydraulically operated controls requiring no unusual effort.
- He climbed in and out of the backhoe two or three times during the morning.
- Lancaster developed worsening chest pain, notified his supervisor, was transported by paramedics to a hospital, and was diagnosed with an acute anterior myocardial infarction.
- Lancaster had significant preexisting risk factors, including a long smoking history, elevated cholesterol, elevated uric acid, and borderline diabetes.
- Medical opinions conflicted on causation: his treating physician linked the event to altitude/cold/work conditions; a panel cardiologist attributed the event primarily to preexisting disease with only minor work contribution; an insurer’s physician viewed it as normal disease progression.
- An administrative law judge adopted the medical panel’s findings and denied workers’ compensation benefits, concluding the heart attack was unexpected but not tied to any unanticipated or unusual work occurrence.

## Issues

1. Whether a heart attack occurring during routine work at high altitude in cold conditions qualifies as an “injury by accident arising out of or in the course of employment” under Utah workers’ compensation law.
2. Whether the claimant proved both legal causation (increased employment-related risk beyond nonemployment life) and medical causation (material contribution by work conditions) for an internal injury.

## Decision

- The Utah Supreme Court affirmed the Industrial Commission’s denial of benefits.
- The court applied the internal-injury framework requiring proof of both legal causation and medical causation.
- The court agreed that Lancaster’s work activity was routine and did not constitute unusual exertion or an unanticipated work occurrence sufficient to establish legal causation.
- The court upheld the Commission’s weighing of conflicting medical evidence and found substantial evidence supporting the conclusion that medical causation was not established.

## Legal Principles

- For internal failures (e.g., heart attacks), compensability requires both:
  - legal causation: employment must expose the worker to an increased risk compared to ordinary nonemployment life; and
  - medical causation: competent medical evidence must show work-related conditions significantly contributed to the internal injury.
- Routine work, without unusual exertion or a work-related increased risk, generally fails legal causation for internal injury claims.
- Appellate review of workers’ compensation causation findings is limited; findings supported by substantial evidence will not be disturbed even when medical testimony conflicts.

## Conclusion

The court held that Lancaster’s heart attack was not compensable because his routine work did not create a legally sufficient increased risk and the Commission, supported by substantial evidence, credited medical testimony attributing the event primarily to preexisting disease rather than work conditions.


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