Brown v. N.C. Dept. of Corre., I.C. NO. 498007.

Plaintiff, 54, employed since 1979 by defendant-employer as an Intensive Surveillance Officer.
On January 25, 2005, plaintiff, while driving a defendant-employer vehicle, was involved in a motor vehicle collision causing head, ears (tinnitus), and neck injuries.
Emergency treatment diagnosed cervical sprain and low back sprain; later reports included tinnitus and vertigo; referred to ENT.
Audiology tests in 2005 showed bilateral hearing loss at 500, 1000, 2000, 3000 Hz (avg ~12.5 dB R, 15 dB L) with ongoing tinnitus.
Dr. Albernaz linked some hearing loss and all tinnitus to the January 25, 2005 collision; warned of possible future hearing aids; plaintiff remained employed.
Full Commission awarded permanent inner-ear injuries (tinnitus) and related medical benefits; denied occupational hearing loss; awarded attorney fees and costs; no Form 21 or final award; §97-47 not applicable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 1/25/2005 accident caused hearing loss.	Plaintiff’s hearing loss is causally linked to the collision.	Hearing loss may not meet statutory occupational loss thresholds.	Cause proven; some hearing loss attributed to accident.
Whether plaintiff suffers occupational loss of hearing under §97-53(28)(b).	Plaintiff’s hearing impairment constitutes occupational loss.	Does not meet statutory frequency/degree requirements for occupational loss.	No occupational loss; not meeting statutory thresholds.
Whether plaintiff has a permanent injury to an important body part (inner ears) under §97-31(24).	Permanent inner-ear injury warrants compensation.	Not all inner-ear injuries qualify under §97-31(24).	Permanent tinnitus and inner-ear injury found; compensable under §97-31(24).
Whether plaintiff is entitled to future medical treatment and potential hearing aids.	Plaintiff bears substantial risk of future medical needs.	Future medical care may be warranted but needs basis.	Entitled to medical treatment and lifetime medical compensation for probable future needs.
Whether there was a change of condition under §97-47.	§97-47 may apply if a Form 21/final award exists.	No Form 21 or final award; §97-47 inapplicable.	§97-47 does not apply; no change of condition found.

Little v. Penn Ventilator Co., 317 N.C. 206, 345 S.E.2d 204 (N.C. 1986) (established standards for medical compensation and Little rule cited in workers' comp)