Celentanto v. Dept. of Corrections

Background:
In a case involving issues similar to those in the Bryant v. Masters Machine case, the Law Court revisited under what circumstances work injuries combine with pre-existing physical conditions resulting in disability that is compensable under the Workers’ Compensation Act. The employee suffered from pre-existing herniated discs and severe spinal disease, which the Hearing Officer found had resolved until a non-work-related injury in 2001. The Hearing Officer found that the 2001 injury arose out of the employment and contributed to the employee’s disability in a significant manner. The employer/insurer appealed the decision.

Court ruling: 
Although the Hearing Officer did not refer to Bryant in her decision, the Maine Supreme Court found that she applied the standard for legal causation set out in that opinion. After hearing a description of the table legs and learning that another employee also caught his foot on the table leg, the Hearing Officer determined that the table leg contributed a substantial element to increase the risk of the employee sustaining a disability.

The Court then found that the remaining elements of Section 201(4) were met because the Hearing Officer, relying on one of the doctor’s opinions, determined that the combination of the work injury and the pre-existing condition rendered the employee disabled and the disability was contributed to by the employment in a significant manner.

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