Injury and Accident: Natural Progression

Kruzich v. Old Republic Ins. Co. [06/01/06] 2006 MTWCC 23 There is a clear distinction between the deterioration or worsening of a condition and the development of an entirely distinct disorder.
Cooper v. Chevron Corp. [3/05/03] 2003 MTWCC 16 The insurer liable for a worker's industrial injury is liable for treatment of the natural progression of that injury.

Liberty Northwest Ins. Corp. v. Burch and Champion Int'l Corp. [11/27/95] 1995 MTWCC 100 Where the only medical opinion concludes that claimant suffered from “continued” impingement of his right shoulder, and claimant testified he suffered no new dislocations or trauma but simply had pain in certain activities, the predecessor employer is responsible for the condition as a natural progression of a prior injury.

Irish v. State Compensation Ins. Fund [4/10/95] 1995 MTWCC 26 Where medical evidence along with claimant’s testimony indicates that his current condition results from the 1977 work injury, he is entitled to medical expenses related to that condition.