South Coast Framing, Inc., Petitioners v. Workers’ Compensation Appeals Board, Jovelyn Clark…

Summary

The court held that a work-related injury need only be a contributing cause of an employee’s death to support workers’ compensation death benefits; it need not be a significant, substantial, or material factor under a heightened standard. Applying substantial-evidence review, the court concluded that evidence supported findings that medications prescribed for the industrial injury contributed to Clark’s drug-related death and that his work-related pain led to a prescription that also contributed to the death. The court therefore reversed the Court of Appeal’s judgment.