Treasurer of the State of Missouri as Custodian of the Second Injury Fund v. Jonathan Parker

Summary

The Court vacated the Commission’s award of permanent total disability benefits because the Commission applied the statutory provision governing injuries before January 1, 2014, even though the primary injury occurred afterward. The Court held that the governing provision does not require a preexisting disability to have reached maximum medical improvement before the primary injury, and that multiple qualifying preexisting disabilities may be considered while nonqualifying disabilities may not. The Court also held that the attached medical records were admissible as part of the complete medical report, although attachment to the notice alone would not have made them admissible.