Lee, Justin v. Western Plastics
This interlocutory appeal concerns an employer's challenge to a trial court's finding that an employee's recurrent shoulder dislocations and need for surgery were causally related to a compensable work injury. The employee, Justin Lee, suffered an initial work-related shoulder dislocation and underwent surgery. He subsequently experienced multiple dislocations of the same shoulder while away from work. The trial court concluded there was sufficient evidence to establish a causal link between the subsequent dislocations and the original injury, ordering ongoing medical benefits. The Appeals Board affirmed the trial court's decision, determining that the medical records, taken as a whole, supported the causal relationship and that the employee's subsequent actions did not constitute negligent intervening conduct. The case has been remanded for further proceedings.