In Rakestraw v General Dynamics Land Systems, Inc., 469 Mich 220 (2003), the Michigan Supreme Court addressed the question of whether a symptomatic aggravation of a preexisting condition constituted an “injury” for purposes of workers’ compensation. The Court held that, in order for a symptomatic aggravation of a preexisting condition to be compensable, the employee must prove that a “medically distinguishable” injury resulted from the employment activity or exposure. The Michigan Workers’ Compensation Appellate Commission, in Hale v Borgess Medical Center, 2004 ACO #266, utilized a Michigan Supreme Court decision that had been decided three years before Rakestraw, Connaway v Welded Construction Company, 462 Mich 691 (2000), to provide “some insight into what the Court considered to be evidence of ‘aggravation’ as opposed to a ‘recurrence’ of a preexisting condition”. Hale, p.6. The Appellate Commission found Connaway instructive in interpreting the term “medically distinguishable” condition. The Appellate Commission observed as follows: Pain alone is not conclusive evidence. However, an injury producing continuing pain, subjectively dissimilar from her pre-injury condition, and causing impaired performance of pre-injury activities can constitute an “independent contribution” to the “final condition”, thus resulting in a “medically distinguishable” condition. This new standard for determining what is “medically distinguishable” appears to rely entirely upon the employee’s subjective report of whether his or her pain is different than it was prior to the work-related injury (or activity) and upon the employee’s personal and subjective assessment of whether his or her performance of pre-injury activities has been impaired by the work injury (or activities). The Appellate Commission’s interpretation of Rakestraw seems to neutralize the requirement that the employee show a “medically distinguishable” injury or condition.