Hartford Accident & Indemnity Co. v. Bristol

Certiorari was granted to resolve the conflict between Brown v. Gulf Ins. Co., 141 Ga. App. 819 (234 SE2d 552) (1977), and Hartford Acc. &c. Co. v. Bristol, 145 Ga. App. 796 (245 SE2d 7) (1978).

Code Ann. § 114-709, as amended in 1968 and as applicable in the present case, provides in relevant part that "Notwithstanding any court decisions previously rendered construing this section, 'change in condition,’ as used herein insofar as it relates to section[s] 114-404 and 114-405 shall mean solely an economic change in condition occasioned by the employee’s . . . inability to work or continue to…