2025 Flashback: How South Coast Framing (2015) Still Impacts Workers’ Compensation Death Claims

It has been a decade since the California Supreme Court decided South Coast Framing, Inc. v. Workers’ Compensation Appeals Board (Clark) (2015) 61 Cal.4th 291. Despite the passage of time, this case remains a cornerstone for understanding causation in death claims—especially when multiple medications (both industrial and nonindustrial) are involved.


Brief Recap

  • What Happened:
    Brandon Clark fell at work, suffering injuries to his neck, back, and head. He was prescribed certain medications through the workers’ compensation system, while his personal doctor prescribed additional drugs (including a sleep aid and an anti-anxiety medication).
  • The Tragedy:
    About 10 months later, Clark passed away at home. Toxicology revealed multiple sedatives in his system—some prescribed industrially, others nonindustrially.
  • Legal Outcome:
    1. A Workers’ Compensation Judge (WCJ) awarded death benefits, finding that even a small industrial contribution to an overdose was enough.
    2. The Workers’ Compensation Appeals Board (WCAB) affirmed.
    3. The Court of Appeal reversed, labeling the industrial contribution “insignificant.”
    4. The California Supreme Court reversed the Court of Appeal, reinstating the death benefits award and confirming that an industrial injury or treatment need only contribute to the death, not be the sole or major cause.

Practical Takeaways for Claims Adjusters

  1. Recognize the Low Causation Threshold
    Even a minimal industrial contribution can trigger full liability for death benefits. Workers’ compensation does not require that work be the primary or substantial factor—just that it “contributed” to the outcome.
  2. Evaluate Medication Histories Carefully
    Investigate all medications the injured worker is taking, from both work-authorized and personal physicians. Overlapping prescriptions can create an overdose risk and a compensable claim if any part of that risk is tied to the industrial injury.
  3. Coordinate With Pharmacy Benefit Managers
    Encourage or require a single point of contact for prescription management. This coordination helps identify potentially dangerous drug combinations and reduces the likelihood of disputes over causation later.
  4. Document Ongoing Medical Treatment
    Keep meticulous records on all prescribed medications, dosages, and reported side effects. Thorough documentation helps clarify the extent to which industrial prescriptions contribute to a condition or fatality.
  5. Be Aware of the “Eggshell Employee” Principle
    The employer takes the employee as is. If a worker has preexisting vulnerabilities (e.g., susceptibility to addiction or concurrent health conditions), industrial treatment that exacerbates those vulnerabilities still results in a compensable claim.
  6. No Apportionment for Death Claims
    In California workers’ compensation, you cannot apportion death benefits among multiple causes. Once industrial causation is established—even slightly—the employer/carrier typically bears full responsibility for statutory death benefits.

Final Thoughts

As we head deeper into 2025, South Coast Framing remains a key precedent whenever causation of a death claim is contested. A small industrial link in a multi-drug fatality still suffices for compensability, highlighting the importance of diligent medication oversight, proactive treatment reviews, and comprehensive documentation throughout the life of a claim.

For more insights or support managing your complex and high-exposure workers’ compensation cases, visit us at rjylaw.com. Our experienced defense team is here to help you navigate California’s evolving workers’ compensation landscape.


Disclaimer: This blog post provides general information and should not be construed as legal advice. For specific claims or legal questions, please consult qualified counsel.