Claim of Bruno v. Kelly Temp Service
In 1997, the claimant suffered a noncompensable lower back injury, but continued to work 40-60 hours per week for 18 months without missing work despite intermittent pain and medical treatment. In February 2000, she sustained a work-related lower back injury while working for Eastman Kodak Company. The Workers’ Compensation Board found that her award should be apportioned 75% to the 1997 injury and 25% to the 2000 injury, based on the preexisting condition being symptomatic and actively treated. The appellate court reversed this decision, clarifying that apportionment applies only when the prior condition constitutes a 'disability in a compensation sense,' not merely a symptomatic condition. Since the claimant was fully employed and able to perform her duties effectively, her prior condition was not disabling, and the Board's finding lacked substantial evidence.