Norman Girard v. BlueTriton Brands, Inc. (Decision 26-04)- where ALJ failed to make findings for the basis of determining no legal causation sufficient for appellate review; matter remanded for further finding. The ALJ determined that Girard met his burden of medical causation to establish climbing down off a forklift aggravated a non-symptomatic preexisting left knee arthritic condition and rupturing an abscess, resulting in a total knee replacement. But the ALJ also concluded that planting the left foot on the ground after having placed right foot on the ground did not create conditions of employment presenting an increased risk above that presented by everyday life. The Appellate Division concluded that despite a motion for further findings, the ALJ failed to make findings addressing an analysis of the risks presented in the workplace.
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