Texas Employers' Insurance Ass'n v. Perez
Texas Employers’ Insurance Association appealed a judgment awarding workers’ compensation benefits to Juan Perez. Perez suffered burns to his forearm and chest in November 1980, resulting in extensive scarring. The core legal question was whether disfigurement to the torso constitutes a specific injury under Tex.Rev.Civ.Stat.Ann., art. 8306, sec. 12, or a general injury. The trial court found 40% permanent partial incapacity for both the arm injury and chest disfigurement. The appellate court affirmed that disfigurement to a bodily part distinct from a specifically injured member is compensable under Section 12. However, it reversed and remanded the judgment, directing the trial court to cumulate compensation for the permanent partial loss of use of the arm and the incapacity due to chest disfigurement, as these were separate permanent incapacities to distinct body parts.