Brown v. SAIF, S062420

Claimant injured his back at work (Dec 14, 2008); SAIF initially accepted a lumbar strain and later accepted a combined-condition claim: “lumbar strain combined with preexisting lumbar disc disease and spondylolisthesis.”
Medical development: claimant’s lumbar strain later reached medically stationary status; subsequent symptoms were attributed by an IME to preexisting degenerative conditions unrelated to the accepted strain.
SAIF denied the combined-condition claim (and moved to close it) on the ground that the accepted lumbar strain had ceased to be the "major contributing cause" of the combined condition.
Claimant did not dispute that the accepted strain ceased to be the major cause; he argued instead that "otherwise compensable injury" refers to the whole work incident and all resulting effects (including nonaccepted worsening of preexisting conditions), not just the accepted condition.
ALJ and Workers’ Compensation Board upheld SAIF’s denial; the Court of Appeals reversed, adopting an "injury-incident" (accident-focused) reading and relying in part on legislative history.
Supreme Court granted review, concluded the statutory text, context, prior precedent, and relevant legislative history support treating the "otherwise compensable injury" as the accepted medical condition, and affirmed the Board.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What does "otherwise compensable injury" mean in ORS 656.005(7)(a)(B) for a previously accepted combined-condition claim?	Brown: it means the work accident and all medical effects that flow from it (not limited to accepted conditions).	SAIF: it means the particular medical condition(s) the insurer/employer accepted as compensable.	Held: it refers to the accepted medical condition(s); statutes (ORS 656.262; 656.268) equate "otherwise compensable injury" with the "accepted injury."
May an insurer deny/close an accepted combined-condition claim when the accepted injury ceases to be the major contributing cause?	Brown: insurer cannot close if some nonaccepted, accident-related effects remain major cause.	SAIF: insurer may deny/close when the accepted injury is no longer the major contributing cause; claimant may separately pursue omitted/worsened-condition claims.	Held: Yes; insurer may deny/close under ORS 656.262(7)(b) and ORS 656.268(1)(b) when the accepted injury is no longer the major contributing cause; claimant has statutory remedies to contest scope or file aggravation claims.

PGE v. Bureau of Labor and Industries, 317 Or. 606 (1993) (rules for statutory interpretation)
State v. Gaines, 346 Or. 160 (2009) (text and context govern statutory meaning)
Bauman v. SAIF, 295 Or. 788 (1983) (acceptance fixes scope of compensable conditions)
Multifoods Specialty Distribution v. McAtee, 333 Or. 629 (2002) (accepted injury may be denied when no longer major contributing cause)
SAIF v. Sprague, 346 Or. 661 (2009) (compensable injury understood as the accepted medical condition)
Hopkins v. SAIF, 349 Or. 348 (2010) (burden-shifting in combined-condition cases)
Landauer v. State Ind. Acc. Com., 175 Or. 418 (1944) (distinguishing accident date from compensable injury/condition)