LA Worker’s Alleged Illness from Mold in Office Did Not Qualify As Occupational Disease
April 4, 2025

A Louisiana appellate court determined that a woman who was exposed to mold in her office environment was not eligible for workers’ compensation benefits for an occupational disease since her condition did not meet the qualifications of an occupational disease per the state’s Workers’ Compensation Act.

Angela Douglas Lyle worked for Brock Services since 2013 and was working in a trailer on the Valero plant in Norco, LA. She claimed from the very start of job that she witnessed mold throughout the trailer- on air vents, window sills, ceiling tiles and baseboards. She said the amount of mold increased over time. In 2015 she claimed she started to experience symptoms like fatigue, phlegm in her chest and throat, burning watery eyes and sores in her nose. Her symptoms got worse over time and eventually had a nosebleed at work in December of that year, prompting a medical evaluation.

Testing at the office confirmed mold and fungal spores. The trailer was replaced in January 2016. Her headache and nosebleed symptoms stopped but she continued to experience other symptoms. She started to experience pain in other parts of her body and shortness of breath too and resigned on June 19, 2016 because of the progression of her symptoms. In August she started to experience even worse symptoms and was admitted to the emergency room twice later that year. She was diagnosed with sarcoidosis of the lungs and lymph nodes, and filed a claim alleging an occupational disease on November 15th that year. Brock requested a hearing with a workers’ compensation judge who denied her claim, saying that she had not suffered an occupational disease within the parameters of the state’s workers’ compensation laws. Louisiana statute says that an occupational disease is defined as an illness due to conditions characteristic of and peculiar to the trade, occupation, process, or employment in which the employee is exposed to the disease. She appealed, saying her sarcoidosis was caused by her employment at Brock.

But further review determined that her case did not satisfy the definition of an occupational disease as it’s written under the LWCA. She could not provide a causal link between her illness and her work-related duties as a clerical worker, as the court did not find an explanation as to why exposure to mold could be considered a characteristic of clerical work. The appellate court denied her and affirmed the judgement of the workers’ compensation judge, who had granted Brock’s motion for summary judgement and dismissed her claim.

Read the case here.

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