Murray v. Utah Labor Comm'n
Annotate this CasePetitioner was working as a park ranger for Utah State Parks and Recreation when he suffered pain in his lower back after losing then regaining his balance on a boat dock while preparing to go on boating patrol. The Utah Labor Commission denied Petitioner's claim for benefits, concluding that the accident had aggravated a preexisting lower back condition and but that the unexpected wave that caused Petitioner to slightly lose his balance was not the legal cause of Petitioner's injury. The court of appeals affirmed. The Supreme Court upheld the court of appeals' ultimate decision to deny Petitioner compensation benefits; holding (1) the court of appeals erred in applying an abuse of discretion standard of review to the Commission's decision; but (2) even under a nondeferential standard of review, Petitioner failed to establish that his boat accident, rather than his preexisting back condition, was the legal cause of his injury.
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