An ABRAMS LANDAU client who was partially disabled after back surgery relocated to California from Maryland. She then had a brain aneurysm which rendered her totally disabled. When the Insurance Company tried to cut off her benefits, the Workers Compensation Commission ruled in favor of the employee. The Commission found that as she was disabled due to “two causes,” and one was related to the on the job accident, she could continue to receive benefits under the Award Doug Landau won for her after a Hearing in the Alexandria Court house.

There are several cases from the Workers Compensation Commission addressing the two causes rule: Leadbetter, Inc. v. Penkalski, 21 Va. App. 427, 427, 464 S.E.2d 554 (1995); Henrico County Sch. Bd. v. Etter, 36 Va. App. 437, 446-47, 552 S.E.2d 372, 376 (2001) (“The extent or degree to which the work-related cause contributed is not important. It matters only that the work-related cause contributed in some part to claimant’s disability.”)

Other cases that talk about the “two causes rule” include: Ford Motor Co. v. Hunt, 26 Va. App. 231, 237-38, 494 S.E.2d 152, 155 (1997); Amelia Sand Co. v. Ellyson, 43 Va. App. 406, 414, 598 S.E.2d 750 (2004); Shelton v. Ennis Bus. Forms, Inc., 1 Va. App. 53, 55, 334 S.E.2d 297, 299 (1985); Papco Oil Co. v. Farr, 26 Va. App. 66, 75, 492 S.E.2d 858 (1997); Bergmann v. L&W;Drywall, 222 Va. 30, 32, 278 S.E.2d 801, 803 (1981); Ford Motor Co. v. Hunt, 26 Va. App. 231, 238, 494 S.E.2d 152 (1997)