Pratt v. Fraser Paper, Ltd.

2001 ME 102, 774 A.2d 351, 2001 Me. LEXIS 112
CourtSupreme Judicial Court of Maine
DecidedJuly 6, 2001
StatusPublished
Cited by7 cases

This text of 2001 ME 102 (Pratt v. Fraser Paper, Ltd.) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pratt v. Fraser Paper, Ltd., 2001 ME 102, 774 A.2d 351, 2001 Me. LEXIS 112 (Me. 2001).

Opinions

ALEXANDER, J.

[¶ 1] Fraser Paper, Ltd., appeals from a decision of a Hearing Officer of the Workers’ Compensation Board granting, in part, its petition for review. The Hearing Officer awarded total incapacity benefits pursuant to 39 M.R.S.A. § 54-B (1989), repealed and replaced by P.L.1991, ch. 885, §§ A-7, A-8 (codified at 39-A M.R.S.A. § 212 (2001)), but reduced that award by the 20% of the employee’s total incapacity which the Hearing Officer attributed to a subsequent nonwork-related heart attack. 39-A M.R.S.A. § 201(5) (2001). Fraser Paper contends that, pursuant to subsection 201(5), the Board should have awarded benefits pursuant to the partial incapacity statute, 39 M.R.S.A. § 55-B (Supp.1989), repealed and replaced by P.L.1991, ch. 885, §§ A-7, A-8 (codified at 39-A M.R.S.A. §§ 213, 214 (2001)), based solely on the contribution of the employee’s work-related knee injury. We agree with Fraser Paper and vacate the Hearing Officer’s decision.

[353]*353I. CASE HISTORY

[¶ 2] The essential facts are not in dispute. The employee, Ernest Pratt, suffered a work-related knee injury on April 25, 1990. Fraser Paper voluntarily paid Pratt total incapacity benefits beginning in July 1990. In 1991, Pratt suffered a heart attack that the Hearing Officer found was not work-related and not related to his work injuries.

[¶ 3] Later in 1991, Pratt’s doctor determined that the knee injury was a permanent impairment corresponding to a 20% whole person impairment. Pratt then began spending a substantial portion of his time in Florida, while spending summers in St. John, New Brunswick. In 1993 and 1995, Pratt was evaluated by his doctor who noted that Pratt was active, was “doing well” and was suffering from “minimal pain and discomfort.”

[¶ 4] In 1995, Pratt saw an orthopedic surgeon in Florida complaining of painful swelling in his injured knee associated with “playing an excessive amount of golf and not limiting his exercise program.” The next summer, another doctor noted swelling in the knee which Pratt reported was because he had “overdone it during the winter walking, line dancing, and playing golf.” In this same assessment, the doctor noted that Pratt was “doing well” with “good stability, no infection, no drainage, no phlebitis, no dysfunction.” A similar assessment was provided in 1997.

[¶ 5] In 1997, Fraser Paper filed a petition for review of incapacity, seeking to reduce benefits. The Hearing Officer concluded that Pratt met his burden to show a lack of available employment within his local community.1

[¶ 6] The Hearing Officer also found that, considering Pratt’s work-related right knee injury alone and excluding consideration of the nonwork-related heart condition, Pratt was capable of “full-time semi-sedentary employment within certain parameters.” The Hearing Officer concluded, however, that based on the “totality of the employee’s physical limitations,” Pratt was physically incapable of performing full-time work in the statewide labor market, and, therefore, was entitled to total incapacity benefits pursuant to former 39 M.R.S.A. § 54-B, repealed by P.L.1991, ch. 885, § A-7.2 See Lamphier v. Bath Iron Works Corp., 2000 ME 121, ¶ 1, 755 A.2d 489, 490; Adams v. Mt. Blue Health Ctr., 1999 ME 105, ¶ 18, 735 A.2d 478, 483-84. The Hearing Officer concluded that Pratt’s heart condition “is the substantial factor in [354]*354the employee’s total incapacity.” (Emphasis added). Although the Hearing Officer concluded that Pratt is entitled to benefits pursuant to the total incapacity statute and that the heart condition was the substantial factor in Pratt’s total incapacity, the Hearing Officer reduced Fraser Paper’s liability by only 20% based on the contribution of Pratt’s nonwork-related heart condition to his incapacity. Fraser Paper challenges only the total incapacity determination and urges that Pratt should have been awarded 80% partial incapacity benefits. We granted Fraser Paper’s petition for appellate review pursuant to 39-A M.R.S.A. § 322 (2001).

II. DISCUSSION

[¶ 7] Subsection 201(5) provides:

5. Subsequent nonwork injuries. If an employee suffers a nonwork-related injury or disease that is not causally connected to a previously compensable injury, the subsequent nonwork-related injury or disease is not compensable under this Act.

39-A M.R.S.A. § 201(5) (2001).

[¶ 8] We first addressed separation of work and nonwork injuries in Mushero v. Lincoln Pulp & Paper Co., 683 A.2d 504 (Me.1996). In Mushero, the employee suffered a work-related heart attack and then a subsequent nonwork-related heart attack. Id. at 505. We construed the former subsection 51(4)3 to require that, in order for an employer to be liable for a subsequent nonwork-injury, the previous work-injury “must in some way bring about or set into motion a sequence of events or conditions that cause the subsequent injury.” The Hearing Officer in Mushero, like the Hearing Officer in the present case, awarded total incapacity benefits pursuant to the total incapacity statute, and then reduced the employer’s liability by 40% of those total benefits attributable to the subsequent nonwork-inju-ry. Id. In Mushero, however, the employee appealed, contending that the Hearing Officer should not have permitted the employer any reduction of its liability for the subsequent nonwork-injury. Id. The issue of which statute for awarding benefits is applicable, section 54-B (total incapacity) or section 55-B (partial incapacity), was not raised in Mushero. Thus, the fact that the employee received benefits pursuant to section 54-B in Mushero is not controlling in the present appeal.

[¶ 9] Fraser Paper contends that, because it is entitled to a reduction in its ongoing liability from total to 80% pursuant to subsection 201(5), the Hearing Officer should have awarded benefits pursuant to the partial incapacity statute, former section 55-B,4 and not pursuant to section [355]*35554-B, the total incapacity statute. The difference is significant because partial benefits under section 55-B are subject to a 400-week limitation and may not be adjusted for inflation. Benefits awarded pursuant to section 54-B are not subject to a 400-week limitation and may be adjusted for inflation. See Lamphier, 2000 ME 121, ¶ 1, 755 A.2d at 490.

[¶ 10] Pratt contends that subsection 201(5) calls for an apportionment between work and nonwork-related causes, and that an apportionment can only be determined after an employee’s level of incapacity is determined based on the totality of the employee’s circumstances, including non-work-related injuries.

[¶ 11] When the Legislature has provided for statutory apportionment, it has stated its intent to create apportionment with express statutory language. For example, section 354, applicable in cases involving multiple work-injuries, expressly provides for an “apportionment” of liability. 39-A M.R.S.A. § 354(3) (2001). Similarly, subsection 201(6) authorizes the Hearing Officer to determine “the portion

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Bluebook (online)
2001 ME 102, 774 A.2d 351, 2001 Me. LEXIS 112, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pratt-v-fraser-paper-ltd-me-2001.