Luton v. Willamette Valley Rehabilitation Center

A diagnosed medical condition arising out of workplace exposure is properly analyzed as an occupational disease rather than a workplace injury, if the onset of the particular condition, rather than the specific symptoms, arises over a gradual period of time.

Luton, the Claimant in this workers compensation matter, appeals an order from the Workers' Compensation Board (the Board), upholding the Employer's denial of compensability. Claimant was employed as a laborer of sorts with Employer, and performed activities such as tightly bundling sticks and repetitively sawing wood. While working, Claimant had a sudden onset of pain in his bilateral wrists, and sought treatment. Claimant was diagnosed with a tear in the triangular fibrocartilage (TFC) in his right wrist, and received surgery for the condition. Claimant sought for the surgery and treatment to be covered as a discrete, compensable workplace injury. Insurer denied the claim based on an IME report from a hand specialist, who opined that Claimant's TFC tear would have developed over a gradual time period, and may be related to an undiagnosed childhood wrist fracture. The ALJ determined that Claimant's injury was compensable and properly analyzed as a discrete workplace injury based on the sudden occurrence of symptoms. The Board reversed the ALJ's order, determining that the claim was properly analyzed as an occupational disease, and that the medical evidence did not support the higher standard of proof requiring Claimant to prove that workplace exposure was the major contributing cause of the condition. Claimant sought judicial review, arguing that the sudden onset of symptoms, rather than the condition as a whole, should be dispositive, and this condition should be analyzed as a discrete injury. The Court disagreed, and held that the onset of the condition, rather than the symptoms alone, is dispositive for determining whether a workers' compensation claim should be analyzed as an occupational disease or workplace injury. Affirmed.