knee developed within twenty four hours, compensation was denied on hearing the medical testimony, and because the employer was predjudiced by lack of notice.65

§ 226. Over Work. In the absence of evidence of an accident, compensation was denied for the death of an officer who worked almost continuously day and night for several days in loading a ship, and died of heart failure six days after the ship left port. The medical testimony was that the death was due to the continuous strain of overwork.66

Where a girl suffered a physical and mental breakdown and aggravation of an old injury as a result of lifting heavy crates and doing other heavy work that was beyond her physicial powers, it was held that this was an injury arising out of the employment.67

Where an employee suffered from a cerebral hemorrhage caused by heat and overexertion, together with diseased arteries, which terminated in paralysis, compensation was allowed.68

An injury is within the act when caused by a strain from rushing work under a time record efficiency system, whereby a strong, healthy man was kept under a high nerve racking tension during every minute of an eight hour work day.69

§ 227. Palmer Abscess.-Where a foreigner suffered from a palmer abscess, caused by the entrance of a sliver into the palm of his hand, compensation was allowed for the injury and doe. tor bills.70

An empolyee received an injury to his hand by reason of extreme pressure exerted while cutting a coil of wire with a shears,

65. Marcontonio v. Charles Francis Press, (1916), 9 N. Y. St. Dep. Rep. 390.

66. Black v. New Zealand Shipping Co., 1913, 6 B. W. C. C. 720; In re Frederick E. Walker, 2nd, A. R. U. S. C. C. 155.

67. Pidgeon v. Maryland Casualty Co., 2 Mass. Ind. A. Bd. 348. 68 Bell v. Hayes Ionia Co., 192 Mich. 90, 158 N. W. 179, 14 N. C. C. A. 532.

69. In re Manning Op. Sol. Dept. Labor, 279.

70. In re Panasuk, 217 Mass. 589, 105 N. E. 368, 5 N. C. C. A. 688.

from which resulted a palmer abscess, and a septic condition without any visible external wound. This was held to be a compensable injury.71

An employee was continually handling a hammer, and developed an abscess on his hand as a result of a break in the callous on the palm. Compensation was allowed for the accidental injury, despite the fact that no definite time could be assigned to the occurrence of the break.72

While an employee was cranking an engine it kicked back and injured his hand which injury developed into a palmer abscess. This was held to be an accidental injury.73

§ 228. Paralysis.-An employee was awarded compensation for paralysis following heavy lifting. The court reversed the findings because it appeared that the Industrial Board made its award on a finding that the applicant, prior to the time he became dizzy, had fallen down a stairway. There was no evidence tending to show that this fall was in any way connected with the employment."

Where an employee received a fall while carrying planks on a spillway, and later died from paralysis, compensation was allowed, even though the testimony was conflicting as to the cause of the paralysis. The award was affirmed by the appellate court on the ground that the finding of the board was final as to the facts.75

Where a coal miner suffered paralysis, following a blow on the head by a falling mine prop, compensation was allowed for total disability.70

71. Erickson v. Mass. .Employees Ins Assn., 2 Mass. Ind. Acc. Bd., 149, 11 N. C. C. A. 496.

72.

Zavella v. Naughton, 2 Cal. I. A. C. 688.

73. Judson v. Southern Cal. Gas. Co., 2 Cal. I. A. C. 254,

74.

Bradley Mfg. Works. v. Ind. Bd. of Ill., 283 IL 468, 119 N. E, 615, 17 N. C. C. A. 250, 2 W. C. L. J. 226; Barrett Co. v. Indust. Com., 288 III. 39, 123 N. E. 29.

75. Homan v. Boardman River Elect. Light & Power Co., 200 Mich. 206, 166 N. W. 860, 1 W. C. L. J. 1043, 17 N. C. C. A. 790. 76.

Frey v. Kerens-Donnewald Coal Co., 271 III. 121, 110 N. E. 824, 15 N. C. C. A. 527; In re Edward Kinney, 2nd A. R. U. S. C. C. 125.

Where an employee had a pre-existing disease known as syphilis, and through an accident this disease was aggravated, causing paralysis and insanity, the court affirmed an award allowing compensation."

Where continued work in an excessively hot room resulted in a rupture of the cerebral blood vesssl of an employee suffering from arterio sclerosis, the finding that the strain, upon the arteries caused by overexertion and excessive heat resulted in a rupture of a blood vessel in the brain causing paralysis was sustained.78 Where a workman strained himself while lifting a barrel, and suffered from apoplexy and paralysis, compensation was awarded."

A workman received an electric shock which threw him against a bench with such force that the heart action was suddenly accelerated, causing a slight hemorrhage of the brain, resulting in paralysis. His incapacity was held to be due to an injury, and compensation was allowed.80

Where an employee, while at work, fell out of a window sustaining serious bodily injuries resulting in paralysis, the arbitration board allowed compensation.81

An employee operating an elevator imagined that he saw a fellow employee about to be killed, and immediately sustained a stroke of paralysis, resulting later in his death. Medical testimony indicated that the paralysis, due to a hemorrhage in the brain, might be caused either by a severe mental shock or by cerebral embolism due to former diseased heart condition, in which case the supposed mental shock might never have occurred in fact but be purely a hallucination due to the cerebral embolism. Such evi

77. In re Crowley, 223 Mass. 288, 111 N. E. 786, 14 N. C. C. A. 141; Romme v. Atl. Screw Works, 1 Conn. I. A. C. D. 108.

78. La Veck v. Park Davis & Co., 190 Mich. 604, 157 N. W. 72, 14 N. C. C. A. 141.

79. Fowler v. Risedorph Bottling Co., 175 N. Y. App. Div. 224, 161 N. Y. Supp. 535, 14 N. C. C. A. 533; Schmidt v. O. K. Baking Co., 1 Conn. C. D. 362, 14 N. C. C. A. 539; Lynch v. Great Atlantic & Pacific Tea Co., 1 Conn. C. D. 163.

80. Milliken v. United States Fideilty & Guar. Co., Mass. W. C. C. (1913) 187, 7 N. C. C. A. 647.

81. Todd v. Grand Trunk R. R. Sys. Mich. I. A. Bd. (1914), 4 N. C. C. A. 852.

dence is not sufficient to prove that the paralysis and death were due to an accidental injury.82

A workman fell and struck his head, and was unconscious for a half hour, but thereafter showed no signs of injury or cerebral trouble. Cerebral hemorrhage and paralysis occurred three weeks afterwards, and caused death, but were held not to be due to the accident.83

Where a gas fitter, who inhaled coal gas, died two days later of paralysis, but had also had previous attacks of paralysis, the paralysis and death were held not to be due to the gas poisoning.8

Where paralysis was gradually brought on by riding a carrier tricycle, it was held that there was no evidence of an accident.85 Compensation was allowed to an employee for the loss of a hand rendered useless through paralysis following an injury to his fingers, 86

Where a fireman, while attempting to clear a passageway of iron beams, felt a pain in his stomach and became weak, and later suffered a paralytic stroke, it was held that his injury was due to an accident.8

87

88

Paralysis caused by an embolism, where the employee suffered no traumatic accident, was held not to be a compensable injury." Where a telephone operator sought compensation for facial paralysis, alleged to have been caused by pressure of the headpiece, worn by the operator, compensation was denied, because medical testimony showed that the paralysis was not due to the wearing of the ear phone.s

Paralysis caused by an acute attack of anterior poliomyelitis was held not to be the result of an injury when the employee fell

82. Keck v. Morehouse, 2 Cal. I. A. C. D. 264 (1915), 10 N. C. C. A. 1048

83.

84

McAdoo v. Cudahy Packing Co., 2 Cal. I. A. C. D. 512. Dean v. London & N. W. R. R. Co., 3 B. W. C. C. 351 C. A, 85. Walker v. Hockney Bros., 2 B. W. C. C. 20 C. A.

86. Floccher v. Fidelity & Deposit Co. of Md., 221 Mass. 54, 108 N. E. 1032.

87 Manning v. Pomerene, 101 Neb. 127, 162 N. W. 492.

88.

Mohr v. Cranford, Inc., 7 N. Y. St. Dep. Rep. 376.

89. Wilson v. Pac. Tel. Co., 1 Cal. I. A. C. Part 2, 414.

into ice cold water ten days previous, hence compensation under the Federal Act was denied.00

Where the claimant was struck on the head by a swinging door but not with sufficient violence to make a mark on his head, it was held that subsequent paralysis did not result therefrom.1

§ 229. Periarthritis.—Where an employee was struck on the elbow by a falling board, and developed periarthritis, compensation was allowed.92

§ 230. Peritonitis.-Where an employee, suffering from an electric shock, later died from peritonitis, compensation was denied because of failure to show any causal connection between the accident and the cause of the death.93

Where a workman slipped and fell on a spillway while carrying planks, and later died from peritonitis caused by paralysis of the brain, it was held that death was due to the accidental fall, and compensation was allowed.94

Where a bargeman slipped while attempting to climb out of a prism of a barge canal, striking his abdomen, which aggravated a diseased appendix, causing an acute exacerbation thereof, producing a rupture from which acute peritonitis developed, causing death, compensation was allowed.95

One employee turned an air hose upon another employee, in the region of the rectum. This caused the victim to suddenly jerk and straighten his body, causing a rupture of an abcess about the gall bladder, from which deceased was suffering. Acute general peritonitis followed, resulting in his death. This was held to be a compensable injury. This "horseplay" having become common.

90. In re Geo. S. Eggleston, 3rd A. R. U. S. C. C. 138. 91. Fink v. Sheldon Axle & Spring Co. Pa. 113 Atl. 666. 92. Jirgens v. St. Comp. Ins. Fund, 2 Cal. I. A. C. 134. Merriman v. Scovil Mfg. Co., 1 Conn. C. Dec. 569. Homan v. Boardman River Light and Power Co., 200 Mich. 206, 166 N. W. 860, 17 N. C. C. A. 790, 1 W. C. L. J. 1043.

93.

94.

95. Lindquest v. Holler, 178 N. Y. App. Div. 317, 164 N. Y. Supp. 906, 14 N. C. C. A. 432; Western Indem. Co. v. Indus. Acc. Comm., Cal., 168 Pac. 663, 1 W. C. L. J. 478.