Case Discussed: Caekaert v. State Compensation Mutual Insurance Fund,
268 Mont. 105, 885 P.2d 495 (1994)

Liberty Mutual v. Griner [11/09/01] 2001 MTWCC 58 Caekaert holds that the insurer liable for a prior work-related occupational disease is not liable for a second, post-MMI injurious exposure which "materially or substantially contributed" to the condition requiring treatment or giving rise to disability.

Liberty NW v. State Fund [10/12/01] 2001 MTWCC 56 Where claimant suffers an industrial injury but reaches maximum medical healing with respect to the injury and thereafter suffers an occupational exposure which permanently aggravates the underlying injury-related condition, the insurer at risk at the time of the subsequent occupational exposure is liable for the medical condition and disability resulting from the aggravation. Caekaert v. State Compensation Ins. Mut. Fund and Liberty Northwest Ins. Corp. v. Champion Intern. Corp. applied.