The Parsons presumption is a rule that future medical treatment related to a proven Workers' Compensation injury is presumed to have arisen from that injury. This shifts the burden from the injured worker back to the insurance company to produce evidence that the new medical treatment is not related to this injury. In Gonzalez v. Tidy Maids, the NC Court of Appeals recently ruled that the Parsons presumption also applies to injuries that are resolved with a Form 63, which allows the insurance company to make payment on the claim (for medical treatment or lost wages) without admitting liability. In Gonzalez, the worker, a maid, was injured in an on the job car accident. The Defendant paid her comp benefits pursuant to a Form 63 "Notice to Employee of Payment of Compensation Without Prejudice." 

The Defendants never denied the claim, but nearly a year later tried to terminate her benefits on the ground that she was no longer disabled. Plaintiff contested that application, citing recurring pain. The Defense countered that the pain was unrelated, and their motion to terminate benefits was granted. However, Ms. Gonzalez appealed the termination to the full Industrial Commission and prevailed, receiving an order of back benefits in addition to reinstatement. In affirming the ruling of the full commission the appellate court ruled that even though she had never proven damages or liability (because she didn't need to; the insurance company just paid her) she was still entitled to the presumption, because the defendant did not contest the claim.