Lewis v. McCracken Motor Freight

Claimant seeks review of a Workers’ Compensation Board order holding that he is not entitled to an award of permanent partial disability. The issue is whether the 1987 amendments to ORS 656.295(5) changed the requirement that he prove a worsening of his left knee condition since the last determination order. We affirm.

The Board found that claimant had compensably injured his left knee in February, 1986. The claim was closed in September, 1986, by a determination order that awarded no permanent disability. Claimant continued to experience pain and eventually underwent arthroscopic surgery in…