New Haven Terminal Corp., and Liberty Mutual Insurance Co. v. Richard Lake and Director, Office of Workers' Compensation Programs, U.S. Dept. Of Labor

Worker Wins Partial Victory in Complex Injury Case

This case involved Richard Lake, a worker who suffered two separate injuries while working for New Haven Terminal Corp. Lake had an injury in 1993, then another injury in 1997. The main dispute was whether New Haven Terminal had to pay workers' compensation benefits for Lake's disability after the 1997 incident, or whether his problems were still related to the earlier 1993 injury.

The lower court had ruled that Lake had completely recovered from his 1993 injury, which would have made New Haven Terminal responsible for compensation after 1997. However, the appeals court disagreed with this conclusion, finding there wasn't enough evidence to prove Lake had fully recovered from the first injury.

The appeals court sent the case back to the lower court for another review of who should be responsible for Lake's ongoing disability and compensation payments after 1997. The court didn't make a final decision about liability.

What this means for workers: When you have multiple work injuries over time, determining which employer or insurance company is responsible for ongoing benefits can be complicated. Courts will carefully examine medical evidence to determine if you truly recovered from earlier injuries before later ones occurred.