Claimant, a lineman, filed claim for workers' compensation benefits for back injury. Claimant's chiropractic records show that claimant had a significant preexisting condition involving same area of the body, and involving same modes of treatment. A claimant may obtain compensation under the Workers Compensation Act even when he suffers from a preexisting condition of ill-being; recovery depends on claimant's ability to establish that his work-related accident aggravated or accelerated his preexisting condition. Causation in preexisting injury cases may be established without medical opinion evidence and through circumstantial evidence, i.e., a chain of events. Record contains sufficient evidence to show that claimant's work accident aggravated his preexisting back condition of ill-being. Section 8.1b does not make submission of a PPD impairment report a prerequisite to an award of PPD benefits by the Commission.(HOLDRIDGE, HUDSON, and STEWART, concurring; HOFFMAN, specially concurring in part and dissenting in part.)
Illinois Appellate Court
Civil Court
Workers' Compensation