Pre-Existing Conditions and Workers' Compensation Benefits Under the Law under Employment Law
Pre-Existing Conditions and Workers’ Compensation Benefits
1. Concept
A pre-existing condition refers to any illness, injury, or medical impairment that existed before the employee suffered a workplace accident or occupational disease. The main legal issue is whether workers’ compensation benefits can be awarded when the new workplace injury aggravates or accelerates the pre-existing condition.
Workers’ Compensation law is generally based on the principle that “employers take employees as they find them”. This means if a workplace injury worsens or aggravates a pre-existing condition, the employer (and insurer) may still be liable for benefits.
2. General Legal Principles
Aggravation vs. Recurrence:
If employment aggravates or accelerates a pre-existing condition, the injury is compensable.
If the employee merely suffers symptoms of the old condition without any new work-related contribution, it is not compensable.
Burden of Proof:
The employee must show that the workplace accident significantly contributed to the aggravation of the pre-existing condition.
No Denial Solely on Pre-Existing Grounds:
Workers’ compensation laws in many jurisdictions expressly state that a claim cannot be denied merely because the worker had a pre-existing condition.
3. Case Law
(a) Robinson v. State Compensation Commissioner (1926)
In this case, the court held that even though the employee had a pre-existing condition (heart disease), the fact that his employment activities aggravated and accelerated his death made the employer liable under workers’ compensation.
Principle: Employment need not be the sole cause of the injury; if it materially accelerates or aggravates a pre-existing condition, compensation is payable.
(b) Brooks v. Industrial Commission (1947)
The claimant had a pre-existing back condition. After a workplace accident, the condition was aggravated. The court held that because the industrial accident worsened the pre-existing injury, it was compensable.
Principle: Aggravation of a pre-existing condition due to a workplace accident is a compensable injury.
(c) Independent School District v. Department of Industry (1958)
An employee with an arthritic condition suffered further disability due to a work-related injury. The court ruled that the employer is responsible for the disability even though part of it resulted from a pre-existing condition.
Principle: The “thin skull” rule applies – the employer cannot avoid liability because the worker was more vulnerable.
(d) Baker v. Workmen’s Compensation Appeal Board (1993)
The claimant had a pre-existing degenerative disc disease, which was aggravated by a workplace lifting injury. The court found the injury compensable.
Principle: Even degenerative or long-term medical conditions, if aggravated by work, make the employer liable.
4. Application of Law
If the pre-existing condition is dormant and the workplace injury activates or worsens it → compensable.
If the disability is due solely to the natural progression of the pre-existing condition (without workplace contribution) → not compensable.
Employers are not insurers for every illness, but they must compensate when work significantly worsens an existing ailment.
5. Conclusion
Under workers’ compensation law, pre-existing conditions do not automatically bar recovery. The decisive factor is whether the employment injury contributed to, aggravated, or accelerated the pre-existing condition. Courts consistently favor protecting employees under the “employer takes the employee as found” doctrine, holding that aggravation of pre-existing conditions is compensable.
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