The Supreme Court of Missouri on Monday ruled a former manufacturing employee’s disability is likely the result of preexisting conditions and not a workplace injury, deeming him ineligible for permanent disability with the state’s Second Injury Fund.

Robert March injured his hands through repetitive motion while working as a meat cutter for 15 years; he later suffered extremity injuries while working in manufacturing, fabricating metal electrical boxes that ranged in weight from 10 to 500 pounds, according to documents in Robert March v. Treasurer of the State of Missouri-Custodian of the Second Injury Fund, filed in Jefferson City.

Court records state that “(b)efore Claimant suffered the primary injuries underlying his workers compensation claim, he endured other health issues, including: morbid obesity, thyroid issues, hypothyroidism, hypertension, a transient ischemic attack, atrial fibrillation, asthma, a second left rotator cuff tear, and a left leg laceration. Claimant's left leg injury, inflicted during a hunting trip, eventually required treatment for stasis ulcers, affected his ability to stand, and created blood flow issues. The most significant of Claimant's preexisting medical conditions was his bilateral lower extremity condition for which he was diagnosed in 2005 with edema and pain radiating down both legs into his ankles, secondary to morbid obesity, and venous varicosities associated with obesity.”

On applying for permanent and total disability benefits under the state’s Second Injury Fund, which covers injuries suffered during multiple employment, his claim was rejected on the premise that he failed to prove his disability was caused by workplace injuries. An administrative law judge issued a ruling denying the benefits, finding Mr. March’s “preexisting disabilities, ‘primarily the lower extremity condition, was actively being treated and was disabling at the time of (his) work-related (claim), which involved inoperable bilateral carpal tunnel injuries.’”

The state’s industrial commission agreed, as did the state supreme court, which held “the commission appropriately found it was not persuaded the combination of his preexisting disabilities and his primary injuries entitled him to PTD benefits because it was ‘equally likely’ his preexisting disabilities alone rendered him permanently and totally disabled.”