Claim of Garcia v. Brassiere Restaurant
A claimant with a known pre-existing brain condition suffered a lacerated scalp at work. Subsequently, the claimant developed cerebellar degeneration and became permanently and totally disabled. An impartial neurologist determined that while the claimant experienced minor head and neck pain causally related to the accident, the severe disability stemmed from a progressive degenerative disease and a posttraumatic seizure disorder, neither of which were found to be causally related to the work accident or exacerbated by the pre-existing condition. The Workers’ Compensation Board relieved the Special Fund from liability, concluding that the pre-existing impairment did not materially and substantially increase the permanent disability beyond what the subsequent injury alone would have caused. The appellate court affirmed the Board's decision, citing substantial evidence.