Hopkins v. SAIF Corp., 349 Or. 348

Summary

The Supreme Court of Oregon interpreted the term "arthritis" in ORS 656.005(24)(a)(A), which governs preexisting conditions in workers' compensation claims. The court held that arthritis means inflammation of one or more joints caused by infectious, metabolic, or constitutional causes and resulting in breakdown, degeneration, or structural change. It concluded that substantial evidence supported the Workers' Compensation Board's finding that Barbara Hopkins had preexisting arthritis and affirmed the denial of benefits.

Holdings

1. For purposes of the workers' compensation statute, "arthritis" means inflammation of one or more joints due to infectious, metabolic, or constitutional causes and resulting in breakdown, degeneration, or structural change. The term is not limited to inflammation of mobile or freely articulating joints.
2. The Workers' Compensation Board did not err in finding that Hopkins had preexisting arthritis because substantial evidence permitted the Board to find inflammation of a joint caused by progressive degeneration and resulting in structural change.

Questions Presented

1. What is the statutory meaning of "arthritis" in ORS 656.005(24)(a)(A) for purposes of establishing a preexisting condition in a workers' compensation claim?
2. Whether substantial evidence supported the Workers' Compensation Board's finding that Hopkins had preexisting arthritis under that definition.

Disposition

affirmed