Hopkins v. SAIF Corp.
245 P.3d 90
| Or. | 2010Background
- Hopkins filed a workers' compensation claim for a thoracic spine injury after work-related bending incident; SAIF denied the claim.
- ALJ and board ultimately found Hopkins suffered preexisting arthritis under ORS 656.005(24)(a)(A) and denied benefits.
- The term 'arthritis' was to be interpreted under SB 485 (2001) as to preexisting conditions, with a special exception for arthritis not requiring prior diagnosis or treatment.
- The case proceeded through the Board, Court of Appeals, and now the Oregon Supreme Court to determine the legal meaning of 'arthritis' and its application to Hopkins's record.
- Expert medical testimony offered competing definitions: some treating doctors described arthritis broadly as joint inflammation; others tied Hopkins's condition to degenerative disc disease and aging.
- The Supreme Court ultimately held that 'arthritis' means inflammation of one or more joints due to infectious, metabolic, or constitutional causes and resulting in breakdown or structural change, and that substantial evidence supported a preexisting arthritis finding in Hopkins.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of arthritis in ORS 656.005(24)(a)(A) | Hopkins argues arthritis is a fixed, narrow definition (mobile joints only). | SAIF contends arthritis includes inflammation of joints from infectious/metabolic/constitutional causes and degeneration. | Arthritis defined as inflammation of one or more joints due to infectious, metabolic, or constitutional causes, causing breakdown/degeneration. |
| Substantial evidence supporting preexisting arthritis | Record lacks evidence that inflammation was due to infectious/metabolic/constitutional causes or caused structural change. | Record shows progressive degeneration with inflammatory joint changes sufficient to prove arthritis. | Board's finding of preexisting arthritis supported by substantial evidence; denial affirmed. |
Key Cases Cited
- SAIF v. Sprague, 346 Or. 661 (Or. 2009) (major contributing cause standard for injuries with preexisting conditions)
- Gasperino v. Albany General Hospital, 113 Or. App. 411 (Or. App. 1992) (discussion of preexisting conditions and major contributing cause)
- Karjalainen v. Curtis Johnston & Pennywise, Inc., 208 Or. App. 674 (Or. App. 2006) (fixed legal meaning of arthritis (pre-SB 485 interpretation))
- Worldmark The Club v. Travis, 161 Or. App. 644 (Or. App. 1999) (arthritis and degenerative disc disease distinctions)
- Wells v. Wells, 15 Or. App. 507 (Or. App. 1973) (arthritis described in older case law)
- McHorse v. Portland General Electric, 268 Or. 323 (Or. 1974) (arthritis described as degenerative changes)