Preexisting Symptoms Can't Be Included in Combined Condition Claim

The Oregon Court of Appeals ruled that the symptoms of a worker’s preexisting shoulder condition could not be combined with the preexisting condition itself to give rise to a combined condition claim. Case: In the Matter of Carrillo, Nos. 1303729 and A169786, 03/17/2021, published. Facts and procedural history: Mario Carrillo worked for the Medford School District as a custodian. He filed a workers’ compensation claim when he began experiencing problems with his left shoulder after a day of heavy lifting at work. The district had workers’ compensation insurance with the SA...