Harman-Bergstedt, Inc., D/b/a Kentucky Fried Chicken and Zurich American Insurance Company v. Elaine Loofbourrow And…

Summary

The court held that an authorized treating physician’s determination of maximum medical improvement did not bar temporary total disability benefits when the worker’s initial injury caused no compensable work loss and only became compensable after a later worsening. Because maximum medical improvement has statutory consequences only for injuries eligible for disability indemnity benefits, the worker was not required to obtain a division-sponsored independent medical examination before seeking benefits. The court affirmed the court of appeals.