The Utah Supreme Court upheld workers' compensation benefits for a teacher attacked while at work. The case is Granite Sch. Dist. v. Young, 2026 LX 498928 (Sup.Ct. 2026).
Background
Robyn Young worked as a special education resource teacher for the Granite School District. She worked full time and had direct interaction with students with disabilities. In 2013, a sixth-grade student head-butted her in the face three times, causing a concussion. She was diagnosed with a concussion, received treatment, and returned to work a month later.
In 2014, a third-grade student punched her in the face and ripped out chunks of her hair. The second incident was more severe than the first one. Young went to an occupational medicine clinic and was diagnosed with a closed-head injury. She returned to work but continued having headaches and needed to go to the emergency room twice.
Young was then diagnosed with post-concussive headaches and depression. In July 2014, her initial treating physician diagnosed her with severe complications from recurrent migraines, attributing them to cumulative head trauma from the work injuries. Her symptoms included facial droop, limb weakness, ear pain, light sensitivity, and erratic foot movements.
In February 2015, her physician cleared her for light duty employment consisting of six to ten hours a week, no more than two hours a day, in a low-light, low-noise environment. Three days later, the Granite School District told Young it would not accommodate her restrictions and terminated her.
Five months later, a second physician evaluated Young and determined that she suffered a mild head and facial injury and was medically stable in 2014, opining that her symptoms were not a result of the work accident. A third physician agreed with the second physician, finding that preexisting psychological factors played a major role in Young's symptoms.
Administrative History
Young filed for workers' compensation benefits, and a medical panel found that the accidents caused or worsened her conditions. The administrative law judge (ALJ) awarded temporary total and temporary partial disability benefits and ordered Granite to cover her medical expenses. The Labor Commission Appeals Board affirmed the award.
In November 2018, Young filed a second workers' compensation claim, this time seeking permanent total disability benefits. Her new treating physician stated she had functional limitations, including recognizing and correcting mistakes, sustaining a regular schedule, and following instructions.
Granite countered with a psychologist who attributed her condition to preexisting psychological factors unrelated to her work injuries. The new medical panel concluded that all of Young's functional restrictions traced back to the 2013 and 2014 accidents, and that her other stressors only caused temporary reactions.
The ALJ relied on the medical panel's report and found by a preponderance of the evidence that Young's restrictions were "based entirely on her industrial medical condition." Granite was ordered to pay historical and future medical expenses and permanent total disability benefits. The Labor Commission affirmed, and Granite petitioned for judicial review.
Utah Supreme Court
The court of appeals certified the case to the Utah Supreme Court. Granite first asserted that the Commission never properly instructed the medical panel to separate industrial from non-industrial causes of Young's injuries, resulting in a flawed report.
The court disagreed, finding that the ALJ's questions explicitly asked the panel to identify the impact of each work accident against the non-industrial stressors, including her divorce and financial stress. The panel concluded the non-work-related stressors only caused temporary reactions.
Six Elements for Permanent Total Disability
Utah Code § 34A-2-413(1) requires proof of six elements by a preponderance of the evidence for permanent total disability claims. Granite challenged the commission's findings on five of the six elements.
The first element is that the employee sustained significant impairment as a result of a work accident. Granite argued that a physician did not formally provide Young with an impairment rating and that her subjective account does not satisfy the element.
The court disagreed, finding that the statute does not require a precise impairment rating. The second treating physician's report was enough to satisfy the element, finding that Young suffered from impairments that resulted in functional limitations.
The second element is that the employee is not gainfully employed, which the Labor Commission determined was satisfied at the time of the hearing. The Commission stated, "while she has worked a limited and irregular schedule since the accidents and receives some financial benefit from her role as an online sales representative, the Commission does not view these activities as gainful employment."
Granite argued that Young was capable of gainful employment since she completed a master's degree, worked as an online sales rep, and volunteered at her child's school. The court agreed with the commission, finding that her role as a sales rep only generated $25 to $37.50 a week from selling to her friends and family. The court determined that did not qualify as gainful employment.
The next element is limited ability to perform basic work activities. Granite argued that Young's educational, work, volunteer, and exercise history showed that she had the "ability to regularly and consistently appear for a scheduled activity, follow directions, openly communicate with others, perform tasks within a limited time period, and reflect more than average endurance, mental capacity and professional skills."
The court again cited the treating physician's report which stated Young had limitations in using reason, working at a consistent pace, sustaining an ordinary routine and regular work attendance, following orders, among other limitations.
The final element is direct cause, establishing a direct link between the disability and the work accidents. Granite argued that the commission's causation finding is not supported by the evidence. The court stated that direct cause means medical cause, and in turn a but-for cause. "In cases where there is no preexisting condition contributing to a disability, the employee need only prove that the work accident is the medical cause of the disability."
Granite again argued that Young's disability could be attributed to both preexisting conditions and post-accident stressors, including generalized anxiety and major depressive disorder.
However, the medical panel found that since Young had no history of headaches before the accidents, her injuries could not be attributed to preexisting conditions. In addition, they found that the post-accident stressors only caused temporary reactions and did not contribute to her permanent restrictions.
Editor's Note
The Utah Supreme Court affirmed the Labor Commission's order awarding permanent total disability benefits. The court reviewed the elements required in the Utah Code to prove a worker is owed permanent total disability benefits and ruled in favor of Young.
The court heavily relied on the findings of the medical panel and the second treating physician, showing the importance of having documented medical evidence in certain cases.
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Ray Sugrim
Ray Sugrim is an Insurance Editor with FC&S Expert Coverage Interpretation, a division of National Underwriter Company and Arc Network. Ray is responsible for helping develop and edit content for subscribers. Ray is a St John’s University graduate with a degree in Risk Management & Insurance and is a CPCU candidate.