Brown, Hayden

Hayden Brown, a mental health technician at Enki Medical Services, was found dead on the floor of her office shortly after the clinic closed; she had previously described her job as high-stress. The WCJ found that her death arose out of and occurred in the course of employment by applying the 'death inference' under Clemmens, finding her death occurred under mysterious circumstances. Defendants sought reconsideration, arguing the death inference was misapplied, Clemmens was distinguishable, the WCJ relied on hearsay, and the heart failure was idiopathic. The QME, Dr. Markowitz, gave equivocal testimony, opining she probably died of a heart attack or malignant arrhythmia that could have been spontaneous or precipitated by work stress, and ultimately deferred to the trier of fact. The Board granted reconsideration to further study whether the death inference applies and whether the record needs development to support Dr. Markowitz's causation opinion, and deferred a final decision after reconsideration.