Sapko v. State

Summary

The court affirmed the denial of survivor's workers' compensation benefits because the decedent's excessive, simultaneous ingestion of Oxycodone and Seroquel was an intervening superseding cause that broke the causal connection between his compensable work injuries and his death. It held that the superseding-cause doctrine remains applicable in workers' compensation cases and that the substantial-factor standard does not eliminate the commissioner's authority to find proximate cause lacking when the relationship is too attenuated. The court also deferred to the commissioner's fact findings and credibility determinations. No separate opinions were issued.