Commission Applied Wrong Burden of Proof on Widow's Death Claim

The Missouri Court of Appeals on Tuesday revived a widow's claim for benefits after her husband suffered a fatal heart attack while working in 100-degree weather. The court said the Labor and Industrial Relations Commission had erred in requiring the widow of Ulysses White to show that White's work conditions were the prevailing factor in causing his death. All the widow had to do was show that White's heart attack arose from a risk of employment by a preponderance of the evidence, the court said. The case was White v. ConAgra Packaged Foods, No. WD79449. White spent 24 years w...