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Home / Courts / Workers’ Compensation – Death Benefits – Course of Employment – ‘Pickrell’ Presumption (access required)

Workers’ Compensation – Death Benefits – Course of Employment – ‘Pickrell’ Presumption (access required)

Gray v. United Parcel Services, Inc. A defense expert testified that decedent’s death was unrelated to his work and was the result of an acute cardiac event. The expert’s testimony was sufficient to rebut the Pickrell presumption that decedent’s death arose out of decedent’s employment, and the Industrial Commission failed to properly complete the remainder of the Pickrell analysis. We remand for a determination of whether the widow met her burden of proving that the death arose out of the course and scope of employment.

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