The Supreme Court of Appeals of West Virginia held that a miner’s pancreatitis was work-related and is compensable, upholding a West Virginia Board of Review’s decision.

Mr. Chaffin worked as a maintenance foreman for Blue Creek Mining in Charleston, WC. He alleged that he developed acute pancreatitis in the course of his employment. On June 10, 2016 he used a chain ratchet to pull a concrete slab when he slipped an fell on the outstretched chain, with all his weight landing on his abdomen. He stayed at work that day but on the way home his co-worker, who he carpools with, said they had to pull off several times for him to vomit and his co-worker took him to the hospital.

On June 11, 2016, treatment notes from Logan General Hospital indicated he was treated for abdominal pain and vomiting and was diagnosed with acute pancreatitis, fatty liver and acute kidney injury. He said he had been experiencing nausea, vomiting, and severe abdominal pain at work. It was noted that his pancreatitis was attributed to trauma after he fell on a suspended chain on June 10, 2016, he had no prior history of pancreatitis and no other cause could be found. He was readmitted to the hospital on June 23, 2016 and it was discovered he had a hemorrhage in his pancreas.

An independent medical examiner performed an exam in December that year and said it was unrelated to the work incident, noting that he was already taking several medications that could cause acute pancreatitis. He had also complained of stomach pain prior to his fall on the chain. As a result, a claims administrator rejected his claim on December 27, 2016.

The Office of Judges reversed the claim administrator’s rejection and said that when he was treated at Logan he was diagnosed with acute pancreatitis with no history of chronic pancreatitis, and he had had previous stomach pain but no nausea and vomiting like he experienced the day of the fall. They found that the IME failed to identify any specific medications that could be the cause of his illness. The Workers’ Compensation Board upheld those findings.

When Blue Creek appealed the appellate court said, “by a preponderance of the evidence that he sustained an injury in the course of and resulting from his employment on June 10, 2016, and that injury resulted in acute pancreatitis.”

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