Agnes N Cramer v. Transitional Health Services of Wayne

Summary

The Michigan Supreme Court held that the exclusive application of the four-factor Martin test conflicted with the plain meaning of the workers’ compensation statute and improperly imposed a heightened burden on claimants with preexisting conditions. The Court overruled Martin to that extent and adopted a clarified totality-of-the-circumstances approach requiring consideration of all occupational, health, and nonoccupational factors. Because the magistrate applied Martin, the Court vacated the magistrate’s findings, reversed the Court of Appeals, and remanded for reconsideration under the clarified standard.