## Facts

- Danny Vredenburg, a bartender, suffered an accepted industrial back injury after slipping on stairs at work.
- Despite surgery and extensive pain management (including strong medications and a morphine pump), he continued to experience severe, chronic pain and was diagnosed with failed back syndrome.
- Medical evidence described his pain as intractable and associated with psychological disturbance; a physician found him unfit for work and recommended permanent disability.
- Vredenburg became socially withdrawn and experienced significant functional and emotional decline.
- About one month after the permanent-disability recommendation, he left suicide notes, told a friend he could not cope with the pain, and died by suicide; a physician opined the suicide resulted from chronic pain.
- His surviving spouse sought workers’ compensation death benefits, alleging the suicide was caused by the industrial injury and resulting pain.
- The administrator denied the claim; a hearing officer and appeals officer affirmed; the district court denied judicial review.

## Issues

1. Whether workers’ compensation death benefits are barred by the statutory exclusion for “willful intention to injure himself” when an employee’s suicide is allegedly caused by an industrial injury.
2. What causation standard governs when determining whether a suicide is “willful” under the exclusion.

## Decision

- The Nevada Supreme Court reversed the district court’s denial of judicial review and remanded for further proceedings before the appeals officer.
- The court held that a suicide is not “willful” for purposes of the exclusion if the claimant proves a sufficient chain of causation.
- The court adopted a three-part test requiring proof that: (1) the employee suffered an industrial injury; (2) the injury caused a psychological condition severe enough to override rational judgment; and (3) that condition caused the suicide.
- Remand was required because the administrative decision was not made under the newly announced standard.

## Legal Principles

- Under NRS 616C.230(1), benefits are barred when death results from the employee’s “willful intention to injure himself.”
- A suicide is not “willful” within the meaning of NRS 616C.230(1) if a claimant establishes a chain of causation from industrial injury to a judgment-overriding psychological condition to suicide.
- Compensability in suicide cases turns on causation and the effect of the injury-related psychological condition on rational volition, not on a categorical rule treating all suicides as willful self-injury.

## Conclusion

Nevada permits workers’ compensation death benefits for an employee’s suicide when the claimant proves that an industrial injury caused a severe psychological condition overriding rational judgment and that condition caused the suicide; the case was remanded for administrative findings under this standard.


Vredenburg v. Sedgwick CMS, 188 P.3d 1084 (Nev. 2008)