SUICIDE RCW 51.32.020)
Permanent total disability at time of death (RCW 51.32.050(6
A spouse, substituted as the appealing party where the worker died during the pendency of the appeal, who established that the worker was permanently totally disabled as of the date his time-loss compensation benefits were terminated, two years before his suicide, was entitled to benefits under RCW 51.52.050(6). ....William Zygarliski, Dec'd.,89 1094 (1990)
RCW 51.32.020 only applies when compensability hinges on the cause of the death. That statute does not bar a claim for benefits by a surviving spouse where the worker's death by suicide takes place while the worker is in a status of permanent total disability. ....John Hoerner, Dec'd., 67,267 (1985) [Rule upheld by Department of Labor & Indus. v. Baker, 57 Wn. App. 57 (1990)]
While the death of a worker who commits suicide with intent and deliberation is not compensable under RCW 51.32.020, the surviving spouse is not foreclosed from benefits under RCW 51.32.050(6) if the worker was permanently totally disabled at the time of death. ....Owen Larkin, Dec'd., 18,441 (1965) [dissent] [Rule upheld by Department of Labor & Indus. v. Baker, 57 Wn. App. 57 (1990)]
Volitional act
Suicide does not bar compensation unless it is a volitional act, i.e., the product of a free exercise of choice. ....David Erickson, Dec'd.,65,990 (1985)