Davidson v. SAIF Corp.

Stepp v. SAIF, 304 Or 375, 745 P2d 1207 (1987), holds that in order to obtain an increased award of permanent disability on a worsening claim filed pursuant to ORS 656.273(1), a worker must show that the condition resulting from the original injury has permanently worsened since the earlier disability award. The threshold question in this case, as in Stepp, is whether the claimant has established a permanently worsened condition.

The Court of Appeals first held that he had, Davidson v. SAIF, 78 Or App 187, 714 P2d 1117 (1986), and increased his permanent partial disability award. SAIF…