In it’s recent decision in Paige v City of Sterling Heights, the Michigan Supreme Court overruled its prior decision in Haggerman v Gencorp Automotive, regarding its interpretation of the phrase “the proximate cause” in the statutory provision regarding the compensability of an employee’s death when it occurs sometime after the occupational injury. In the Paige case, the employee was employed as a firefighter. He suffered a heart attack while performing firefighting duties on the job. However, he survived the heart attack, but was medically limited from returning to work as a firefighter. A magistrate granted an open award of benefits. The employee lived another nine years. He sustained a second heart attack and died five months later in his sleep. The employee’s minor child filed a claim for workers’ compensation death dependency benefits pursuant to MCL 418.375(2), which provides that, if the work related injury was “the proximate cause” of the death, death dependency benefits are payable to surviving dependents. The case was eventually tried, and the magistrate awarded death dependency benefits to the surviving child. The Appellate Commission affirmed the magistrate’s decision. It relied upon the definition of “the proximate cause” in the Haggerman case. In Haggerman, the Supreme Court had construed the phrase “the proximate cause” to mean “a substantial factor” in causing the event. The employer appealed to the Court of Appeals. The Court of Appeals declined to review the case. The Michigan Supreme Court agreed to review the case. The Court overruled its construction of the phrase “the proximate cause” in the Haggerman case, and adopted its construction of the phrase from a case it had more recently decided, construing the same phrase in the Governmental Tort Liability Act, Robinson v Detroit. In Robinson, the Court had construed the phrase “the proximate cause” more narrowly to mean “the one most immediate, efficient, and direct cause”. Accordingly, the Supreme Court vacated the decision of the Appellate Commission and remanded the case for reconsideration. In summary, the Court’s ruling in Paige will hold surviving dependents of employees who die sometime after a work related injury to a more stringent causation standard in order to recover workers’ compensation death dependency benefits. Employee’s dependents will have to prove that the work injury was “the one most immediate, efficient, and direct cause” of death in order to receive benefits.