Benefits Awarded Where Intoxication Was Not 'Proximate Cause' of Injuries

The Alaska Supreme Court unanimously affirmed a workers compensation verdict for a man who, though he admitted to being intoxicated shortly before the incident, had a compensable injury because it would have happened whether or not he was intoxicated. The case is State of Alaska v. Adams, 2022 Alas. LEXIS 117 (Alaska 2022). 

Virgil Adams fell 30 feet when the supports beneath the ladder he was standing on collapsed; the fall left him totally and permanently disabled. Hospital tests revealed, and Adams freely admitted, that Adams had both cocaine and alcohol in his system at the time of the accident. Adams also admitted that he had not examined the cribbing before climbing up the ladder. There was no workers compensation policy in place, so Adams filed a claim with the Workers Compensation Fund (Fund), which denied his claim based on the presence of the drugs.