Fred Meyer, Inc. v. Evans

Employer seeks review of an order of the Workers’ Compensation Board (Board) upholding the compensability of claimant’s neck surgery. Its principal contention on review is that the Board applied the wrong standard of proof by treating claimant’s case as a claim for a “combined condition” instead of a “consequential condition.” We affirm.

The following facts are not in dispute. Claimant worked as a receiving clerk for employer. In 1992, she was hit by a forklift while working. Employer accepted claimant’s claim for shoulder, knee, and foot injuries. When other symptoms occurred, claimant…