Crown, Cork & Seal v. Smith

¶1 This case asks the court to determine what constitutes a “previous bodily disability” entitling an employer to second injury fund coverage under RCW 51.16.120(1) of the Industrial Insurance Act. Division Two of the Court of Appeals held that Crown, Cork & Seal (Crown) was not entitled to second injury fund coverage because any injury to the employee did not substantially impact the employee’s daily functioning and efficiency. We affirm.

FACTS

¶2 In 1980, Sylvia Smith began employment with Crown, a manufacturer of beer and soda cans. Smith worked as a *870bagger, a job requiring her to push a…