Benninger v. Weyerhaeuser Co.

In this workers’ compensation case, we review for substantial evidence. Armstrong v. Asten-Hill Co., 90 Or App 200, 752 P2d 312 (1988).

The referee held, on the basis of detailed findings of fact, that claimant’s lower back condition was compensable as a material worsening of a 1985 on-the-job injury. On de novo review, the Board reversed. The Board’s order is inadequate for judicial review. Although the order concludes that claimant’s condition is the result of an off-the-job injury, it contains inadequate findings or explanation to support that conclusion. “When the Board reverses, adequate…