In Barrett Business Services v. Hames, 130 Ore. App. 190, 881 P.2d 816 (1994), Hames suffered a compensable dislocation of his right shoulder when he fell from a ladder scaffold at work. During treatment for his shoulder, Hames developed a "frozen shoulder." During physical therapy to treat Hames' frozen shoulder, Hames' right ulnar nerve was injured. Hames' employer denied Hames' workers' compensation claim and the referee upheld that denial. The workers' compensation board reversed, and awarded Hames' benefit for his ulnar nerve injury. The Oregon Court of Appeals affirmed the board's decision, stating that Hames' ulnar nerve injury was compensable because that injury was a direct result of pursuing a reasonable and necessary course of treatment, that being physical therapy for his compensable shoulder injury.