Wood v. Fletcher Allen Health Care

739 A.2d 1201, 169 Vt. 419 (1999)

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Wood v. Fletcher Allen Health Care

Vermont Supreme Court
739 A.2d 1201, 169 Vt. 419 (1999)

Facts

In November 1995, Paula Wood (plaintiff) suffered a work-related injury during her employment with Fletcher Allen Health Care (FAHC) (defendant). Wood received temporary total-disability benefits. In mid-1997 Wood was pregnant, and her physician recommended having surgery for her work-related symptoms from the injury after she gave birth. On August 14, 1997, FAHC notified Wood and the workers’-compensation commissioner that her temporary benefits would be discontinued on August 21. Following her physician’s recommendation, Wood received surgery for her injury in June 1998 after she gave birth in February. To support the discontinuance, FAHC argued that the pregnancy was a superseding intervening cause of Wood’s condition, that her pregnancy was a flare-up of her condition up until she gave birth, and that Wood refused recommended medical treatment. The commissioner found the evidence did not support a discontinuance and allowed payments to continue pending a hearing. The commissioner distinguished between Wood’s pregnancy and her injury, finding that her work injury was the cause of her continuing disability, not her pregnancy, and her inability to work continued until Wood had surgery. At the hearing, the commissioner determined that Wood’s benefits should not be discontinued as a result of her pregnancy. FAHC filed a motion for reconsideration, but it was denied. FAHC appealed.

Rule of Law

Issue

Holding and Reasoning (Dooley, J.)

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