Claim of Saunders v. Pepsi Cola
On December 28, 1989, the claimant sustained a lower back injury while working, leading to two surgeries and workers' compensation benefits. X-rays revealed a pre-existing condition of spondylolisthesis. The employer's workers' compensation carrier sought to impose liability on the Special Disability Fund under Workers' Compensation Law § 15 (8) (d). The Workers' Compensation Board concluded that the claimant's disability was solely caused by the 1989 accident and discharged the Special Disability Fund. The Appellate Division affirmed this decision, finding substantial evidence that the spondylolisthesis was asymptomatic and did not contribute to the subsequent disability.