Court: Compensability Determination or Admission Required to Reopen Claim for Change in Condition

The Colorado Court of Appeals in a case of first impression held that a workers' compensation claim can be reopened for a change in condition only if there was an admission or determination that the injury was compensable before it was closed. Because there was no determination on the compensability of Lusia Murillo's claim before it was closed for failure to prosecute, the court said it affirmed the Industrial Claim Appeals Office decision that it was not eligible to be reopened. Murillo claimed she injured her lower back working as a housekeeper for the Ritz-Carlton, Bachelor Gulch...