Anderson v. Chrysler Corp
In Anderson v. Chrysler Corp, 189 Mich App 325; 471 NW2d 623 (1991), the plaintiff suffered from a preexisting skin condition known as "hyperkeratosis palmaris."
While in contact with oil and grease during his work with the defendant, the plaintiff experienced flare-ups of contact dermatitis, lesions, and rashes due to his exposure to the grease and oil.
In reversing a WCAB award of open benefits and holding that the plaintiff was entitled only to a closed award for the period in which his flare-ups continued.
The Court stated:
The plaintiff's situation is very similar to that of the plaintiffs in Thomas v. Chrysler Corp, 164 Mich App 549; 418 NW2d 96 (1987) supra, Durham v. Chrysler Corp, 128 Mich App 102; 339 NW2d 705 (1983), and Carter v. General Motors Corp, 361 Mich 577; 106 NW2d 105 (1960) supra.
Those cases held that work which causes an aggravation of symptoms only, and not an acceleration or aggravation of the underlying condition, entitles a plaintiff to a closed award at most. 164 Mich App 555. Nezdropa v. Wayne Co, 152 Mich App 451; 394 NW2d 440 (1986), cited by plaintiff, is distinguishable because once plaintiff's rash and pain subsided he was perfectly capable of working. He admitted as much. Id. at 329.