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RAKESTRAW APPLIES TO PREEXISTING WORK-RELATED CONDITIONS AS WELL AS PREEXISTING NON WORK-RELATED CONDITIONS

In Zanskas v National Staff Management, Inc., 2003 ACO #224, the Michigan Workers' Compensation Appellate Commission recently held that the Supreme Court's analysis of compensable aggravation in Rakestraw applies not only to alleged occupational aggravations of preexisting non-occupational conditions, but also to claims of work-related aggravations of a preexisting work-related condition. Zanskas, id, at 8.

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