WCAB

The family of Brandon Clark was awarded workers’ compensation death benefits after Clark died from the combination of drugs prescribed following a fall at work. The Court of Appeal overturned the award, reasoning there was insufficient evidence that the drugs prescribed for the work injury contributed to the death. We reverse the Court of Appeal’s judgment.

I. Background

In September 2008, the 36-year-old Clark fell eight to 10 feet while working as a carpenter for South Coast Framing, Inc. (hereafter the employer). He suffered neck and back injuries as well as a concussion. Clark’s workers’ compensation doctor prescribed various drugs to treat these injuries, including Elavil (an antidepressant), Neurontin (a neuronal pain reliever), and Vicodin (a codeine-based pain reliever). In January 2009, Clark’s personal doctor additionally prescribed Xanax (an antianxiety medicine) and Ambien (a sleep aid).

On the morning of July 20, 2009, Clark’s wife was unable to rouse him and he was pronounced dead at the scene. At the time of his death, Clark had Elavil, Neurontin, Xanax, and Ambien in his blood. Vicodin was detected in his urine. The autopsy surgeon concluded the death…