Beaulieu v. Maine Medical Center

In these five consolidated appeals, we address the narrow question whether 39-A M.R.S.A. § 102(4)(H) applies to pre-1993 injuries in proceedings initiated after January 1, 1993, despite Workers' Compensation Board Rule 1.4(B). Me.W.C.B. Rule 1.4(B) (currently Me.W.C.B. Rule 4.2). We conclude that the section does apply to pre-1993 injuries, and accordingly we vacate four of the five decisions.1 As part of the Maine Workers' Compensation Act of 1992, the Legislature enacted the section codified in 39-A M.R.S.A. § 102(4)(H) (Supp. 1995), as follows: