Evergreen Packaging, Inc. v. Prather, 318 Ga. App. 440

Prather claimed a back injury in 2002 and received disability benefits and medical care.
He returned to work as a plate maker in 2005–2006, a more physically demanding role.
The plate-maker duties involved bending, lifting 30–50 pounds, and handling 15–20 pound plates, with more bending due to a new table.
In 2010 Prather developed worsened back symptoms and numbness; MRI showed increased disc extrusion and a new annular tear.
Medical doctors tied the 2010 condition to work-related activity; the ALJ awarded temporary total disability benefits for the 2010 injury.
The Board and superior court upheld the ALJ’s determination that Prather suffered a new injury rather than merely a change in condition; Evergreen appeals.
The central legal issue is whether Prather’s 2010 deterioration constitutes a new injury or a change in condition, reviewed for legal error and supported by evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
New injury or change in condition after 2002	Prather; evidence shows new injury	Evergreen; evidence shows gradual wear/change	Some evidence supports a new injury finding
Effect of altered duties and new table on injury status	Prather’s new duties aggravated pre-existing condition	Wear/tear or gradual deterioration	Evidence supports new-injury finding rather than change in condition
Standards of review for Board findings	Board findings should reflect new-injury evidence	Board findings are binding if supported by evidence	Board findings supported by evidence; de novo review for legal error applied

R.R. Donnelley v. Ogletree, 312 Ga. App. 475 (Ga. App. 2011) (affirms new-accident theory where post-injury work differed from prior duties)
Shaw Industries v. Scott, 310 Ga. App. 750 (Ga. App. 2011) (distinguishes wear-and-tear gradual deterioration from new injury when duties change)
Scott v. Shaw Industries, 291 Ga. 313 (Ga. 2012) (binding confirmation of new-injury framework on appeal)