Lockheed Missiles & Space Co. v. Bobchak

Bobchak (plaintiff) fractured his knee in August of 1987 while working for W. H. Gross Construction Company (Gross). Bobchak underwent surgery and received disability benefits from Gross until October 12, 1987, when he began working for Lockheed Missiles & Space Company (Lockheed) (defendant). In February of 1988, Bobchak experienced weakness in his knee after climbing and descending a ladder at Lockheed. Bobchak’s knee became painful and swollen, and his condition required more surgery. Bobchak sought workers’-compensation benefits for his injured knee. In proceedings before an administrative-law judge (ALJ), Bobchak indicated that he had still experienced occasional pain prior to the ladder incident at Lockheed, and Bobchak’s doctor testified that people with fractures like Bobchak’s could continue to need periodic surgical treatments to address their injuries. The ALJ heard no evidence that Bobchak was heavily exerting himself at the time of the ladder incident or that Bobchak twisted his knee or suffered any other trauma. The ALJ found that Bobchak’s duties at Lockheed were not more strenuous than his duties at Gross and that there had not been an incident at Lockheed that aggravated Bobchak’s prior knee injury. The ALJ thus concluded that Bobchak had experienced a change in condition for which Gross was responsible. The workers’-compensation board affirmed the ALJ’s decision, but the superior court reversed, holding that Bobchak’s injury was the result of a new accident and that Lockheed bore responsibility for compensation. Lockheed appealed to the Georgia Court of Appeals.