Crowe v. Jeld-Wen, Inc.

Claimant seeks judicial review of an order of the Workers’ Compensation Board which reversed the referee’s order holding that claimant had suffered an aggravation of her earlier compensable industrial injury. A back injury sustained in one employment, followed by a worsening of symptoms during a later employment, is involved. The issue is whether the “last injurious exposure” rule applies to impose liability on the second employer. We hold that conditions existed at the second employment that could have, but did not, contribute to the disability, that claimant merely suffered an aggravation…