Worker's Pre-Employment Conditions Require Carve-Out From PPD Rating

The Kentucky Supreme Court ruled that a worker’s pre-employment injury and back surgeries required that an impairment rating be carved out of his permanent partial disability rating after he was hurt on the job. Case: ViWin Tech Windows 85 Doors Inc. v. Ivey, No. 2019-SC-0370-WC, 03/25/2021, published. Facts: Mark Ivey had a history of back problems. In 2004, Dr. Theodore Davies diagnosed Ivey with a lumbar disc displacement with lumbar radiculopathy. He then performed an L4-5 hemilaminotomy with discectomy on Ivey. In 2012, Davies diagnosed "recurrent lumbar disc displacem...