Angela Lyle worked in the payroll department at Brock Services. Her office was in a trailer in Norco, Louisiana, at the Valero plant. Lyle claimed she saw mold throughout the trailer that increased over the two years she worked at the site. She suffered from fatigue, burning eyes, sores, and other symptoms. After suffering a nosebleed, she underwent a medical evaluation. Testing confirmed mold was present in the office, so Lyle’s trailer was replaced. Once the trailer was replaced, some of Lyle’s symptoms went away, but others persisted, and new symptoms emerged.
She resigned and was diagnosed with sarcoidosis in her lungs and lymph nodes. She then filed a claim with the Workers’ Compensation, claiming she had suffered an occupational disease and was entitled to damages. The workers’ compensation judge denied her claim as neither her mold exposure nor the development of sarcoidosis qualified as an occupational disease or accident under the Louisiana Workers’ Compensation Act. Brock filed a summary judgment motion, arguing Lyle could not establish sarcoidosis was an occupational disease. The workers’ compensation judge granted Brock’s summary judgment motion, finding Lyle’s sarcoidosis was not an “occupational disease. Lyle appealed, arguing the workers’ compensation judge ignored the definition of an “occupational disease” under the Louisiana Workers’ Compensation Act.
La. R.S. 23:1031.1(B) defines an occupational disease under the Louisiana Workers’ Compensation Act. The court considers an employee’s work-related duties to determine if an illness is an occupational disease. On appeal, Lyle argued in a recent court case, Arrant v. Graphic Packaging International, Inc., the Louisiana Supreme Court held causation was the primary determinant of whether a claim is compensable as an occupational disease. She argued that this connection between the employment environment and the claimant’s illness was different from the prior duties-based approach, which required a causal link between the claimant’s illness and the claimant’s work-related duties.
The appellate court disagreed with Lyle’s interpretation of Arrant and held there had to be a causal link between Lyle’s illness and her work-related duties. Therefore, the appellate court agreed with the workers’ compensation ruling that granted Brock’s summary judgment motion and dismissed Lyle’s claim.
If you or a loved one have experienced an illness you think resulted from your job, a good attorney can advise you on the requirements to prevail in a claim under the Louisiana Workers’ Compensation Act. This can include presenting evidence to support a causal connection between the illness and your job duties. Otherwise, even if you have been working in a potentially harmful environment, like Lyle’s moldy trailer office, you might be unable to recover.
Additional Sources: Angela Douglas Lyle v. Brock Services, LLC
Article Written By Berniard Law Firm
Additional Berniard Law Firm Article on Causation in Workers’ Compensation Claims: The Challenge of Establishing Causal Links in Workers’ Compensation Claims