Knowlton v. Wood River Medical Center

Appellant Lesia Knowlton appealed the Industrial Commission's determination that she was not entitled to workers' compensation benefits. Appellant was employed as a secretary at Respondent Wood River Medical Center. In 2000, Appellant was working at her assigned station when a drain in a nearby patient's bathroom became clogged. One of the maintenance workers used a chemical cleaner to clear the drain. The chemical produced a foul odor. Workers placed fans at the doorway of the room for ventilation. The air blew past Appellant's station from morning until her shift ended in the afternoon. That night, Appellant developed a cough and body aches. Her symptoms persisted, allegedly from exposure to the chemical drain cleaner. Over the course of five years, Appellant visited multiple doctors and specialists to treat her "bronchitis-like" symptoms. Appellant filed a complaint with the Industrial Commission seeking reimbursement for her medical expenses and for temporary total disability benefits. At a Commission hearing, the referee ultimately concluded that Appellant failed to demonstrate that her medical symptoms were causally related to the chemical exposure. Although the referee determined that Appellant was not entitled to "time loss" benefits or any form of disability benefits, he did find that because the medical treatment Appellant received during the six weeks following the incident was a "reasonable precautionary step" taken in response to the exposure, she was entitled to compensation for those expenses. The Commission adopted the referee's findings of fact and conclusions of law. The Commission denied Appellant's motion for reconsideration. Subsequently Appellant appealed to the Supreme Court. The Supreme Court agreed that Appellant failed to demonstrate her medical symptoms were related to the chemical exposure. Accordingly the Court affirmed the Commission's determination.