Reed Contracting Services, Inc. appealed a decision from the Madison Circuit Court that directed the company and its workers' compensation carrier to approve and cover the costs of bilateral knee-replacement surgeries for their former employee, Henry Riley. Riley had suffered a fall from a "man lift" in March 2012 while working as a tire technician, causing injuries to both his wrists and knees. Subsequent medical evaluations revealed a tear in the medial collateral ligament of his right knee and aggravated arthritis in both knees due to the fall. An orthopedic surgeon, Dr. Jeffrey C. Davis, upon a second opinion, confirmed that the fall exacerbated Riley's pre-existing arthritic condition, making knee replacements necessary.
The primary disagreement was about whether the fall caused a permanent aggravation to Riley's arthritis or just a temporary one. The trial court, in October 2015, ruled that the fall permanently aggravated Riley's arthritis and thus the knee replacements and reinstatement of his temporary-total-disability benefits were justified. Reed Contracting appealed this decision, but the appellate court upheld the trial court's findings. The appellate court noted that under the Workers' Compensation Act, even if a pre-existing condition is aggravated by a work-related injury, the employee is still entitled to compensation. The court also confirmed the necessity to continue disability payments to Riley until he reached Maximum Medical Improvement.
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