Claim of Mandziara v. Lowe's Home Centers
In 1995, the claimant suffered a back injury in Pennsylvania, leading to a workers' compensation claim. After multiple surgeries, symptoms were resolved by June 2001. In May 2003, while working for Lowe's Home Centers in Broome County, the claimant re-injured their back, initiating a new claim. A Workers’ Compensation Law Judge and subsequently the Workers’ Compensation Board ruled that apportionment did not apply to the workers' compensation award. The appellate court affirmed this decision, holding that apportionment is a factual issue and the Board's determination was supported by substantial evidence. The court highlighted the claimant's asymptomatic period of over 14 months prior to the 2003 injury.