VT Sup Crt: Last Exposure Not Apply if Injuries Distinct

The Supreme Court of Vermont held that where the claimant suffers two distinct injuries, liability among carriers can be apportioned and the last injurious exposure rule does not apply. In Farris v. Bryant Grinder Corp. , No. 2003-516, 01/14/2005, Farris had surgery on his knee in 1972 and began working for Bryant Grinder Corp. (Bryant) in 1973. In 1991, Farris slipped on oil at work, and again injured his knee, forcing him to receive medical treatment and undergo an additional knee surgery. Farris was out of work for 15 months and received benefits from Bryant's carrier Wasau (carrier ...