Corey Ferrell v. City of Wilmington IAB

Summary

The Supreme Court of Delaware affirmed the Superior Court's decision upholding the Industrial Accident Board's determination that Ferrell's 2023 back condition was a recurrence of his 2015 injury rather than a new injury or aggravation caused by an intervening event. The Court held that the recurrence-versus-aggravation framework was the appropriate standard for assigning liability between successive employers or carriers and that substantial evidence supported the Board's factual findings. Because Ferrell had commuted and released his 2015 claim, the Board's determination left him without a compensable claim against Wilmington, but that consequence did not make the Board's legal analysis erroneous.