High Court Explains Availability of Apportionment for Worker With Increase in PPD After 2nd Injury

The District of Columbia Court of Appeals ruled that when a worker’s injury increased his preexisting permanent partial disability, his schedule award was not subject to apportionment. Case: Howard University Hospital v. District of Columbia Department of Employment Services (Lyles), No. 20-AA-405, 01/27/2022, published. Facts: James Lyles Jr. injured his right arm at work in 2011. He filed a workers’ compensation claim against his employer and later settled. Meanwhile, Lyles began working for Howard University Hospital. He injured his right arm again in April 2013 and file...