## Facts

- Weston Bryant worked as a machinist for Masters Machine Co.
- On February 28, 1978, while operating a drill press, another employee accidentally kicked out the stool on which Bryant was sitting, causing Bryant to fall to the floor.
- Bryant had “frozen” knees due to a preexisting condition and was unable to break his fall.
- Bryant experienced immediate lower-back pain and, the next day, substantial right-hip pain; prescribed medication did not relieve persistent and sometimes worsening pain.
- Bryant returned to work three days after the fall but later missed one week in November 1978 due to pain and ultimately left work on August 14, 1979, claiming total disability as of that date.
- Before the fall, Bryant reported he could work and perform physical activities without pain; after the fall, he reported significant functional limits, sleep difficulty, and heavy aspirin use.
- Bryant had prior serious accidents in 1960 and 1961 and multiple medical conditions diagnosed later, including rheumatoid arthritis of the right hip, osteoarthritis in the lumbar spine, spondylolisthesis, spina bifida occulta, and degenerative disc disease.
- The commissioner found Bryant’s conditions were preexisting and asymptomatic, and that the fall made them symptomatic without changing their underlying pathology.

## Issues

1. Whether a work-related fall that activates disabling symptoms of a previously asymptomatic preexisting condition constitutes a compensable “personal injury” under Maine workers’ compensation law, even absent a demonstrable change in underlying pathology.

## Decision

- The Maine Supreme Judicial Court vacated the Superior Court’s pro forma judgment affirming the Commission.
- The court held the fall was a compensable injury because it activated the disabling effects of Bryant’s previously asymptomatic preexisting conditions.
- The court ruled the Commission applied an erroneous legal standard by requiring proof of pathological change rather than focusing on work-related causation of disabling symptoms.
- The case was remanded for entry of a decree awarding compensation consistent with the court’s legal rule.

## Legal Principles

- A compensable work injury includes a workplace incident or exertion that “lights up” or activates the disabling effects of an asymptomatic preexisting disease, producing disability causally related to work.
- Compensation does not require proof that the work event altered the underlying anatomical or pathological state; symptom-producing aggravation that causes disability can satisfy the statutory concept of “injury.”
- The relevant causation inquiry is whether the employment incident materially contributed to the resulting disability, not whether it was the sole cause or created new pathology.
- A factfinder’s determination that pathology was unchanged is not dispositive if the evidence shows the work incident activated disabling symptoms.

## Conclusion

The court held that Maine workers’ compensation covers disability resulting when a workplace incident activates the disabling symptoms of a previously asymptomatic preexisting condition, and it remanded for an award because the Commission incorrectly required proof of pathological change.


Bryant v. Masters Mach. Co., 444 A.2d 329 (Me. 1982)