Goodman v. SAIF Corp.

Upon review of a denied claim for a new injury based on a combined condition, the Workers Compensation Board must determine whether the new injury has ceased to be a major contributing cause of or need for treatment for the combined condition.

Goodman’s right wrist and thumb were accidentally injured at work in the scope of his employment. He already had a preexisting injury to his right wrist, as well as arthritis and carpal tunnel syndrome. Goodman made a claim for the new injury, and a separate claim for compensation based on a combined condition. In May 2012 SAIF accepted the first claim, and accepted a combined condition of “right wrist injury combined with prior right wrist scaphoid non-union fracture and post traumatic arthritis.” However, SAIF concluded in October 16, 2012, that the injury was “no longer the major contributing cause” of Goodman’s disability, and denied his claim starting from October 16, 2012. Goodman sought review of the decision; the ALJ concluded that SAIF did not meet its burden of proof to show that the injury was no longer the cause of Goodman’s combined condition and set aside the denial. SAIF challenged this order and the Worker’s Compensation Board reversed, finding that the accepted conditions of Goodman’s claim were not a “major contributing cause” of the combined condition. Goodman appealed the Board’s decision. The Court held that the Board did not apply the standard set in Brown v. SAIF, as it is supposed to determine “whether the otherwise compensable injury . . . has ceased to be the major contributing cause of the worker’s disability or need for treatment for an accepted combined condition.” Reversed and remanded.