Supreme Court of Alaska (2022)
In Workers’ Compensation Benefits Guarantee Fund v. Adams, 518 P.3d 280 (Alaska 2022), the
supreme court upheld the Alaska Workers’ Compensation Board’s (Board) determination that a
carpenter’s intoxication while on the job was not a proximate cause of his fall from a ladder. (Id.
at 281, 287). While repairing a roof, a carpenter fell 30 feet from a ladder when the cribbing
beneath the ladder gave way. (Id. at 282). Prior to the accident, the carpenter admitted to using
cocaine and drinking alcohol at the worksite. (Id.). The Alaska Workers Compensation Act denies
workers’ compensation for injuries proximately caused by an employee’s alcohol or drug use. (Id.
at 285). For a court to find proximate cause, the employer has the burden of proof to show that but
for the worker’s intoxication, the accident would not have happened, and that reasonable people
would regard the worker’s intoxication as responsible for the accident. (Id. at 285). On appeal, the
Workers’ Compensation Benefits Fund argued that the Board’s finding that the drugs and alcohol
were not a but–for cause of the injury was “arbitrary and unreasonable,” because it relied heavily
on the carpenter’s testimony. (Id. 287–88). The court held that the Board had the sole authority to
determine the credibility of a witness, and that the conclusion the Board reached based on the
information before it was reasonable, even if it could have reached a different conclusion based on
different inferences gleaned from the facts. (Id. at 288). Affirming the Board’s finding and the
Workers’ Compensation Appeals Commission’s decision upholding the Board’s finding, the
supreme court held that because a carpenter’s intoxication was not a proximate cause of his fall
from a ladder, the carpenter was entitled to workers’ compensation. (Id. at 281).