Brown v. Patton

I fully agree with the main opinion’s rejection of the so-called “but-for” test of causation under Alabama’s workers’ compensation law and, as a corollary, that opinion’s embrace of the requirement for a showing of “ ‘a definite causal connection between the work and the injury.’ ” 77 So.3d at 594 (quoting Slimfold Mfg. Co. v. Martin, 417 So.2d 199, 202 (Ala.Civ.App.1981)). I write separately because I believe a full understanding of what is meant by the term “causal connection” necessitates some discussion of two other tests that have been expressed in our cases and how these two other tests…