Standards Clarified for Workplace Injuries and Pre-Existing Conditions
What happens when a person is injured at work and it aggravates an existing condition? Workers’ compensation programs have trouble dealing with these situations. Should the injured worker be compensated?
A recent decision by the Tennessee Supreme Court provides important clarification on how workers’ compensation claims involving pre-existing conditions should be evaluated. The ruling reinforces that employees are not automatically barred from receiving benefits simply because they had a prior medical condition.
At the center of the decision is a two-part causation test for “aggravation” injuries. First, an injured worker must show that the workplace accident contributed more than 50% to worsening the underlying condition. Second, the worker must prove that the aggravation itself contributed more than 50% to the need for medical treatment or disability.
The court emphasized that the focus should be on whether the work-related incident caused a meaningful worsening of the condition, not whether the condition existed beforehand. This clarification is significant because many workers suffer from pre-existing issues such as arthritis or prior injuries.
This clarification was put to the test in Jo Carol Edwards v. Peoplease LLC. The court overturned a lower board’s ruling, holding that a workplace injury does not have to result in a permanent worsening of a pre-existing condition to qualify for workers’ compensation benefits.
The case stemmed from an August 2020 crash involving a truck driver who lost control of her vehicle after a tire blowout, resulting in injuries to both knees. Although she had advanced arthritis prior to the incident, she reported being symptom-free and fully able to perform her job before the accident.
Following the crash, she experienced significant pain and was diagnosed with additional injuries, including a knee fracture. Her condition ultimately led physicians to recommend total knee replacement surgeries. The employer’s workers’ compensation insurer denied coverage, arguing that the need for surgery was due to her pre-existing arthritis rather than the accident itself.
The employee maintained that the crash directly caused her need for treatment and resulting disability. Medical experts supporting her claim testified that the incident aggravated her previously asymptomatic condition, making it painful and necessitating surgical intervention.
In contrast, the employer argued that the accident caused only a temporary flare-up of symptoms. Its experts contended that a compensable aggravation required a permanent structural change to the knee, which they claimed did not occur. They maintained that her underlying arthritis, not the workplace accident, was the primary reason for the recommended surgeries.
Ultimately, the court concluded that the employee had met this standard. The accident caused her asymptomatic arthritis to become painfully symptomatic. The court held Peoplease responsible for the woman’s knee surgeries and related temporary and permanent total disability benefits.
Contact Us Today
A workplace accident can aggravate old injuries. This should not bar a person from receiving compensation for damages.
A Mt. Juliet workers’ compensation lawyer from The Law Offices of Christopher Eads, PLLC can guide you through the claims process and help negotiate for maximum possible compensation. We can also help you appeal your claim or escalate your case to a lawsuit. Fill out the online form or calling (615) 622-6060 to schedule a consultation.
Source:
riskandinsurance.com/tennessee-supreme-court-clarifies-workers-comp-standard-for-pre-existing-conditions/
