• Connecticut Appellate Court
  • Lavine, J.
The Supreme Court's 2003 decision in Hatt v. Burlington Coat Factory, that Connecticut General Statutes §31-299b "permits apportionment only in cases of repetitive trauma or occupational disease and, therefore, does not provide a basis for apportionment of liability among insurers when the claimant has suffered two separate and distinct injuries…" was distinguished here, where two separate and distinct, noncumulative knee injuries occurred and the remedial purposes of the Workers' Compensation Act were fostered by the plaintiff undergoing bilaterial knee replacement surgery with one period of recovery.
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