Wyoming Statutes
Wyo. Stat. § 27-14-603 (2026)
Burden of proof; required proof of
✓ current as of May 2026
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circumstances; coronary conditions; hernia.
(a) The burden of proof in contested cases involving
injuries which occur over a substantial period of time is on the
employee to prove by competent medical authority that his claim
arose out of and in the course of his employment and to prove by
a preponderance of evidence that:
(i) There is a direct causal connection between the
condition or circumstances under which the work is performed and
the injury;
(ii) The injury can be seen to have followed as a
natural incident of the work as a result of the employment;
(iii) The injury can fairly be traced to the
employment as a proximate cause;
(iv) The injury does not come from a hazard to which
employees would have been equally exposed outside of the
employment; and
(v) The injury is incidental to the character of the
business and not independent of the relation of employer and
employee.
(b) Benefits for employment-related coronary conditions
except those directly and solely caused by an injury, are not
payable unless the employee establishes by competent medical
authority that:
(i) There is a direct causal connection between the
condition under which the work was performed and the cardiac
condition; and
(ii) The causative exertion occurs during the actual
period of employment stress clearly unusual to or abnormal for
employees in that particular employment, irrespective of whether
the employment stress is unusual to or abnormal for the
individual employee; and
(iii) The acute symptoms of the cardiac condition are
clearly manifested not later than four (4) hours after the
alleged causative exertion.
(c) If an employee suffers a hernia, he is entitled to
compensation if he clearly proves that:
(i) The hernia is of recent origin;
(ii) Its appearance was accompanied by pain;
(iii) It was immediately preceded by some accidental
strain suffered in the course of the employment; and
(iv) It did not exist prior to the date of the
alleged injury.
(d) If an employee establishes his right to compensation
for a hernia as provided and elects not to be operated on, he
shall not be compensated for the results of future strangulation
of the hernia.
(e) In those proceedings in which the entitlement of an
employee to benefits for successive compensable injuries is
established but no single employer can be determined to be
chargeable for the injuries, the division shall apportion the
benefit charge in accordance with W.S. 27-14-201(d).Notes of Decisions
Cited in 59
cases (2 in the last 5 years), 1989–2024 · leading case: Worker's Comp. Claim of Bruns v. TW Servs., Inc., 2001 WY 127 (Wyo. 2001).
Worker's Comp. Claim of Bruns v. TW Servs., Inc., 2001 WY 127 (Wyo. 2001). “Did the Hearing Examiner correctly conclude that Wyo. Stat. Ann. § 27-14-603 (b) is applicable to Appellant's case? II.”
Dougherty v. J.W. Williams, Inc., 820 P.2d 553 (Wyo. 1991). “" The hearing examiner determined that the injury occurred over a substantial period of time; that Wyo. Stat. § 27-14-603 (1987) [2] was the controlling statute; that Dougherty had the burden to prove by competent medical authority that his claim arose out of and in the course…”
Ball v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2010 WY 128 (Wyo. 2010). “injuries occurring from complications of medical treatment of work-related injuries are themselves compensable? The Wyoming Workers' Safety and Compensation Division (Division) states a single issue: Did the Hearing Examiner commit an error of law by analyzing Appellant's injury…”
Loomer v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 88 P.3d 1036 (Wyo. 2004). “What is the “particular employment,” for purposes of Wyo. Stat. Ann. § 27-14-603 (b)(ii), of an employee who is hired as a pipe inspector, but who dies of a heart attack while working as a truck driver? 2.”
KG Constr., Inc. v. Sherman, 2005 WY 116 (Wyo. 2005). “Following a hearing, the hearing examiner ruled the injury was a compensable injury occurring over a substantial period of time under Wyo. Stat. Ann. § 27-14-603 (a) (LexisNexis 2003).”
Sanchez v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2006 WY 64 (Wyo. 2006). “[¶ 10] When an injury 1 arises over time, a claimant’s burden of proof is enhanced by Wyo. Stat. Ann. § 27-14-603 (a) (LexisNexis 2005).”
Sinclair Trucking v. Bailey, 848 P.2d 1349 (Wyo. 1993). “Therefore, the Office looks to the provisions of W.S. 27-14-603 to resolve this matter. I find that direct causal connection exists between the Claimant’s hemorrhoids and the fact that his job required him to spend long periods of time sitting in a moving vehicle.”
Brent Mcmillan v. State of Wyoming, Ex Rel. Dep't of Workforce Servs., Workers' Comp. Div., 2020 WY 68 (Wyo. 2020). “McMillan failed to meet his burden under Wyo. Stat. Ann. § 27-14-603 (a) for an injury occurring over a substantial period of time contrary to the overwhelming weight of the evidence? FACTS [¶3] Mr.”
Worker's Comp. Claim of Decker v. State Ex Rel. Wyoming Med. Comm'n, 2005 WY 160 (Wyo. 2005). “” Because Decker has settled on this position, the Commission’s revised order should analyze Decker’s claim under the heightened burden of proof required by Wyo. Stat. Ann. § 27-14-603 (LexisNexis 2005).”
Sherwin-Williams Co. v. Borchert, 994 P.2d 959 (Wyo. 2000). “Applying Wyo. Stat. Ann. § 27-14-603 (LEXIS 1999) [1] , the hearing examiner found that Borchert's shoulder injury had occurred over a substantial period of time.”
Worker's Comp. Claim of Newman v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2002 WY 91 (Wyo. 2002). “Application of § 27-14-603(a) [134] Ms. Newman also contends that the hearing examiner erred in applying § 27-14-603(a), which pertains to the burden of proof applied to an injury occurring over a substantial time period.”
Bando v. Clure Bros. Furniture, 980 P.2d 323 (Wyo. 1999). “Relying on two alternate grounds, the hearing examiner denied benefits.”
— Wyo. Stat. § 27-14-603(a) — 18 cases
Sinclair Trucking v. Bailey, 848 P.2d 1349 (Wyo. 1993). “Therefore, the Office looks to the provisions of W.S. 27-14-603 to resolve this matter. I find that direct causal connection exists between the Claimant’s hemorrhoids and the fact that his job required him to spend long periods of time sitting in a moving vehicle.”
Worker's Comp. Claim of Newman v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2002 WY 91 (Wyo. 2002). “Application of § 27-14-603(a) [134] Ms. Newman also contends that the hearing examiner erred in applying § 27-14-603(a), which pertains to the burden of proof applied to an injury occurring over a substantial time period.”
Latimer v. Rissler & McMurry Co., 902 P.2d 706 (Wyo. 1995).
Worker's Comp. Claim of Decker v. State Ex Rel. Wyoming Med. Comm'n, 2005 WY 160 (Wyo. 2005). “” Because Decker has settled on this position, the Commission’s revised order should analyze Decker’s claim under the heightened burden of proof required by Wyo. Stat. Ann. § 27-14-603 (LexisNexis 2005).”
Worker's Comp. Claim of Yenne-Tully v. Workers' Saf. & Comp. Div., Dep't of Emp., 12 P.3d 170 (Wyo. 2000).
— Wyo. Stat. § 27-14-603(a)(iv) — 1 case
KG Constr., Inc. v. Sherman, 2005 WY 116 (Wyo. 2005). “Following a hearing, the hearing examiner ruled the injury was a compensable injury occurring over a substantial period of time under Wyo. Stat. Ann. § 27-14-603 (a) (LexisNexis 2003).”
— Wyo. Stat. § 27-14-603(b) — 12 cases
Worker's Comp. Claim of Bruns v. TW Servs., Inc., 2001 WY 127 (Wyo. 2001). “Did the Hearing Examiner correctly conclude that Wyo. Stat. Ann. § 27-14-603 (b) is applicable to Appellant's case? II.”
State Ex Rel. Wyoming Workers' Comp. Div. v. Taffner, 821 P.2d 103 (Wyo. 1991).
Loomer v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 88 P.3d 1036 (Wyo. 2004). “What is the “particular employment,” for purposes of Wyo. Stat. Ann. § 27-14-603 (b)(ii), of an employee who is hired as a pipe inspector, but who dies of a heart attack while working as a truck driver? 2.”
State Ex Rel. Wyoming Workers' Comp. Div. v. Brewbaker, 972 P.2d 962 (Wyo. 1999).
State ex rel. Wyoming Workers' Comp. Div. v. Harris, 931 P.2d 255 (Wyo. 1997).
— Wyo. Stat. § 27-14-603(b)(ii) — 8 cases
Loomer v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 88 P.3d 1036 (Wyo. 2004). “What is the “particular employment,” for purposes of Wyo. Stat. Ann. § 27-14-603 (b)(ii), of an employee who is hired as a pipe inspector, but who dies of a heart attack while working as a truck driver? 2.”
Ball v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2010 WY 128 (Wyo. 2010). “injuries occurring from complications of medical treatment of work-related injuries are themselves compensable? The Wyoming Workers' Safety and Compensation Division (Division) states a single issue: Did the Hearing Examiner commit an error of law by analyzing Appellant's injury…”
Loomer v. State Ex Rel. Div., 2004 WY 47 (Wyo. 2004).
State ex rel. Wyoming Workers' Comp. Div. v. Harris, 931 P.2d 255 (Wyo. 1997).
In the Matter of the Worker's Comp. Claim of: Anita J. Fieseler v. State of Wyoming ex rel. Wyoming Workers' Saf. & Comp. Div., 2013 WY 116 (Wyo. 2013).
— Wyo. Stat. § 27-14-603(c) — 3 cases
Torres v. State Ex Rel. Wyoming Workers'Saf. & Comp. Div., 2005 WY 7 (Wyo. 2005).
Ball v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2010 WY 128 (Wyo. 2010). “injuries occurring from complications of medical treatment of work-related injuries are themselves compensable? The Wyoming Workers' Safety and Compensation Division (Division) states a single issue: Did the Hearing Examiner commit an error of law by analyzing Appellant's injury…”
Ball v. State Ex Rel. Workers'Saf. Div., 2010 WY 128 (Wyo. 2010).
— Wyo. Stat. § 27-14-603(c)(i) — 1 case
Ball v. State Ex Rel. Workers'Saf. Div., 2010 WY 128 (Wyo. 2010).
— Wyo. Stat. § 27-14-603(c)(iii) — 2 cases
Ball v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2010 WY 128 (Wyo. 2010). “injuries occurring from complications of medical treatment of work-related injuries are themselves compensable? The Wyoming Workers' Safety and Compensation Division (Division) states a single issue: Did the Hearing Examiner commit an error of law by analyzing Appellant's injury…”
Ball v. State Ex Rel. Workers'Saf. Div., 2010 WY 128 (Wyo. 2010).
— Wyo. Stat. § 27-14-603(e) — 5 cases
Olsten Temp. Servs. v. State Ex Rel. Wyoming Workers' Comp. Div., 870 P.2d 360 (Wyo. 1994).
L & H Welding & Mach. Co. v. State ex rel. Wyoming Worker's Comp. Div., 876 P.2d 984 (Wyo. 1994).
Romero v. Davy McKee Corp., 854 P.2d 59 (Wyo. 1993).
KG Constr., Inc. v. Sherman, 2005 WY 116 (Wyo. 2005). “Following a hearing, the hearing examiner ruled the injury was a compensable injury occurring over a substantial period of time under Wyo. Stat. Ann. § 27-14-603 (a) (LexisNexis 2003).”
Torres v. State Ex Rel. Wyoming Workers'Saf. & Comp. Div., 2005 WY 7 (Wyo. 2005).
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