Bryant v. Masters Mach. Co. - 444 A.2d 329 (Me. 1982)

Rule:

An employee is entitled to compensation for a disability proximately caused by his employment regardless of whether his condition at the time of injury was average or subnormal. A work injury that aggravates a pre-existing condition is compensable even though a physically normal employee would have been unaffected, provided the injury occurs under conditions that would otherwise entitle the employee to compensation.

Facts:

Appellant employee worked as a machinist for Masters Machine Co. On the day of the incident, the employee was in the course of his employment activities operating a drill-press. He was sitting on a stool, described to be twenty-five or twenty-six inches in height, which another employee accidentally kicked out from under him. Because his knees were "frozen" due to a pre-existing condition, the employee was unable to break his fall, and he fell from the stool directly onto the floor. Appellant employee filed a petition for workers' compensation. The Commissioner, though finding that the injury arose out of and occurred in the course of the employee's job, found that the employee's complaints were non-compensable as an "injury" under the scope of the workers' compensation statute because they were merely aggravations of pre-existing physical impairments. The superior court affirmed. Appellant employee sought review of the decision. 

Issue:

Were the employee’s complaints non-compensable as an "injury" under the scope of the workers' compensation statute because they were merely aggravations of pre-existing physical impairments? 

Answer:

No.

Conclusion:

The court reversed and remanded. The court held that an employee was entitled to compensation for a disability proximately caused by his employment regardless of whether his condition at the time of injury was average or subnormal. A work injury that aggravated a pre-existing condition was compensable even though a physically normal employee would have been unaffected, provided the injury occurred under conditions that would otherwise have entitled the employee to compensation. The fact that a pre-existing condition was in part responsible for the claimant's period of disability does not in itself render the injury non-compensable, though the employee would still have to show proximate causation.