Sapko v. State
The concerns that caused the Connecticut Supreme Court to abrogate the superseding cause doctrine in the 2003 case of Barry v. Quality Steel Products, Inc., are not implicated in the workers' compensation scheme, which in contrast to Connecticut's comparative negligence tort scheme, is a no-fault compensation system that imposes a form of strict liability on employers. The plaintiff, Christine Sapko, sought survivor's benefits following the death of her husband, Anthony Sapko, a state employee. The commissioner denied the claim determining that the decedent's simultaneous ingestion of excessive quantities of Oxycodone, which had been prescribed for compensable work injuries and Seroquel, which had been prescribed for an unrelated case of major depression, constituted a superseding cause of his death and, therefore, that the decedent's compensable work injuries were not the proximate cause of his death. The board upheld the commissioner's decision. The plaintiff appealed to the Appellate Court which agreed with the plaintiff that the board incorrectly concluded that the superseding cause doctrine applied but concluded that this impropriety was harmless because the record otherwise supported the board's determination that the commissioner properly applied the law to the facts in deciding proximate cause. The Supreme Court granted the plaintiff's petition for certification and affirmed the Appellate Court's judgment, albeit on different reasoning. The Supreme Court ruled that the board correctly concluded that the superseding cause doctrine applied to certain cases under the Workers' Compensation Act, C.G.S. §31-275 and that the commissioner's finding that superseding events broke the chain of proximate causation between the decedent's compensable work injuries and his death constituted a proper application of the law to the facts. In Barry, the Supreme Court abrogated the superseding cause doctrine for negligence cases only because, in those cases, a jury is tasked with apportioning liability in accordance with Connecticut's comparative fault and apportionment statutes. Workers' compensation cases are decided by trial commissioners and there is not the same concern that the trier of fact will be confused by the superseding cause concept. Additionally, the plaintiff misplaced reliance on the 2008 Supreme Court's statement in Birnie v. Electric Boat Corp., that an injured employee is entitled to recovery under the act if he can demonstrate that his employment contributed to the injury "in more than a [de minimus] way."