(concurring in part and dissenting in part). I agree with the result the majority reaches in Mudel.
I dissent from the majority’s decision in Connaway and would reverse the holdings of both the Court of Appeals and the Worker’s Compensation Appellate Commission in that case. The wcac exceeded its authority, reversing the decision of the magistrate that was based on competent, material and substantial evidence on the entire record. MCL 418.861a(3); MSA 17.237(861a)(3), MCL 418.861a(14); MSA 17.237(861a)(14), Holden v Ford Motor Co, 439 Mich 257, 269; 484 NW2d 227 (1992).
I write, also, to register my strong disagreement with the majority’s decision to revisit the settled standards of review in worker’s compensation cases. In recent years, this Court has been careful to craft workable standards of appellate review. Holden, Goff,1 and Layman2 are consistent with the Worker’s Disability Compensation Act3 and with each other and do not cause the confusion the majority asserts. It is the majority’s decision in this case that will cause confusion. It will alter the law, expressly overruling Layman and Goff, decisions that are only two and three years old, respectively.
I. GOFF
Today, the majority needlessly reaches beyond the issues presented to overrule precedent. The time-*734honored doctrine of stare decisis strongly encourages courts to adhere to their precedents. A prior decision should be overruled only once a court is convinced that it was both wrongly decided and that less harm will result from overruling than from following it. People v Graves, 458 Mich 476, 480-481; 581 NW2d 229 (1998). In my view, the majority has failed to establish either prong of the Graves test and, thus, has failed to justify the extraordinary act of overruling Goff. I do not think that Goff and Holden can be read as inconsistent with one another.
Holden states that, in reviewing wcac decisions, courts are to ensure that the wcac “did not ‘misapprehend or grossly misapply’ the substantial evidence standard.” If the wcac did not misapprehend its administrative appellate role in reviewing the decision of the magistrate, it should be affirmed. Holden, supra at 269; MCL 418.861a(14); MSA 17.237(861a)(14).
Goff states:
[W]here a party claims that the wcac has exceeded its power by reversing the magistrate, meaningful review must begin with the magistrate’s decision, because if competent, material, and substantial evidence based on the whole record supports the magistrate’s decision, the wcac need go no further. If it does, the wcac is exceeding its authority.
[IcL at 513.]
If the magistrate’s decision is reasonably supported in the record by any competent, material, and substantial evidence, then it is conclusive and the wcac must affirm. If it does not, it is exceeding the scope of its reviewing power and impermissibly substituting its judgment for the magistrate’s. [Id. at 538 (emphasis added).]
*735The majority claims that this language fuses the “substantial evidence” standard, whereby the wcac reviews the magistrate’s decision, and the “any evidence” standard, whereby appellate courts review the wcac’s decision. I disagree.
If a magistrate’s finding of fact is supported by “any” competent, material, and substantial record evidence, then it is supported by competent, material, and substantial evidence on the whole record. The standard of review stated in Goff is the same as in Holden. The mere use of the word “any” does not have the effect of fusing or confusing the “substantial evidence” standard with the “any evidence” standard. Not to put too fine a point on it, “any competent, material, and substantial evidence” is not equivalent to “any evidence.”
While appellate courts review the wcac’s findings of fact under the “any evidence” standard, they are also directed to determine whether the WCAC misapprehended its administrative appellate role in reviewing magistrates’ decisions. Whether the wcac was acting within its powers of review is a question of law. MCL 418.861a(14); MSA 17.237(861a)(14); Holden, supra at 269. The Court of Appeals and Supreme Court review questions of law de novo. Cardinal Mooney High School v Michigan High School Athletic Ass’n, 437 Mich 75, 80; 467 NW2d 21 (1991).
When it is claimed that the wcac substituted its own findings, we determine whether the wcac exceeded its administrative appellate authority by examining the findings of fact of the magistrate. When the latter are plausibly supported by any competent, material, and substantial evidence in the *736record, the wcac should be reversed and the magistrate’s factual findings should be reinstated. To hold otherwise would leave appellate courts powerless to ensure that the wcac acts within its legislatively defined parameters.
[I]t is quite possible that a reasonably minded magistrate could interpret a record differently than a reasonably minded wcac. However, if the magistrate’s conclusion is derived from competent, material, and substantial evidence, then the wcac may not substitute its judgment for that of the magistrate notwithstanding either the reasonableness or the adequacy of the commission’s conclusion. [Goff, supra at 514; MCL 418.861a(3); MSA 17.237(861a)(3).]
The majority notes:
[C]ourts simply cannot review the record in every worker’s compensation case in the detail required to make conclusions about the sufficiency of the magistrate’s decision. Worker’s compensation cases are typically fact intensive, involving lengthy deposition testimony and medical documentation. If the courts were to attempt a review of each and every worker’s compensation case with an eye toward making detailed factual conclusions, dockets would become impossibly burdened with worker’s compensation cases, further delaying the resolution of injured workers’ claims for benefits. [Ante, p 702, n 5.]
However, where the WCAC makes factual findings that conflict with those of the magistrate, a reviewing court is compelled to examine the findings of the magistrate. How else can it determine whether the WCAC misapprehended its administrative appellate role? As a practical matter, this occurs in the course of ascertaining whether the opinion of the WCAC is supported by “any evidence.”
*737“In reviewing the magistrate’s decision, the wcac must do so with sensitivity and deference toward the findings and conclusions of the magistrate in its assessment of the record. . . . Ultimately, the role of the Court of Appeals and [the Supreme] Court is only to evaluate whether the wcac exceeded its authority.” [Layman, supra at 507, quoting Goff, supra at 538.]
While there are constitutional and statutory restrictions on judicial review of the wcac, they pertain to factual conclusions. Const 1963, art 6, § 28, MCL 418.861a(14); MSA 17.237(861a)(14). And the wcac’s factual conclusions are insulated only if made in the course of a proper exercise of the wcac’s review function.
Under the guise of clarifying the standards of review, the majority has, in fact, eliminated meaningful appellate court oversight of the operation of the wcac. Today’s decision essentially restores to the wcac de novo review of magistrates’ decisions, something the Legislature sought to eliminate in 1985. 1985 PA 103. It removes the ability of appellate courts to examine a magistrate’s decision to determine whether the wcac exceeded its appellate role. And it leaves no means by which to compel the wcac’s compliance with the “substantial evidence” standard that the wdca directs the wcac to employ.
The majority acknowledges that an inherent tension exists between the language of subsections 861a(3) and (14). It acknowledges that appellate courts experience difficulties applying the “any evidence” standard to wcac findings of fact while also ensuring that the wcac has acted within its powers when reviewing magistrates’ decisions. Holden, supra at 263, 269. The majority, in “clarifying and defini*738tively setting forth the proper standards of administrative and judicial review,” admittedly fails to resolve this tension. (Ante, pp 696; 695, n 1 and 704, n 6.) Judicial review of the WCAC is still a tightrope walk in most cases. Thus, the majority seems to have accomplished nothing useful here, only to have upset the settled state of the law.
II. LAYMAN
Layman's holding need not be addressed in deciding these cases. In reversing Layman today, the majority has ignored the basic doctrine of ripeness.4 Layman held that, where findings of fact necessary to support a legal conclusion are incomplete, the WCAC must remand to the magistrate for the requisite fact finding. Id. at 509. Neither Mudel nor Connaway implicates Layman or requires the Court to reach the question whether it was wrongly decided.
A. MUDEL DOES NOT PRESENT ISSUES IMPLICATING LAYMAN
In Mudel, the issue is whether the WCAC erroneously changed the statutory basis for the magistrate’s award of benefits from a § 401 occupational disease to a § 301 personal injury.
The magistrate and the WCAC agree that plaintiff suffered from a work-related disabling condition, entitling him to an open award of benefits. The magis*739trate found the disabling condition to be an occupational disease, and the wcac found it to be a personal injury. The differing legal conclusions are based on the same facts. The majority concludes: “[T]he magistrate’s award of benefits to Mudel under § 401 does not necessarily imply a rejection of his qualification for benefits under § 301.” Ante, p 717, n 17.
When the magistrate found that plaintiff’s deep vein thrombosis was a work-related disease, he necessarily first found that the condition was a personal injury. When the wcac reversed the magistrate’s finding that plaintiff’s disability was caused by a work-related disease, it then had to determine whether plaintiff had a compensable personal injury. This is a broader category, one that includes work-related diseases in its definition. The issue is not one of fact that the magistrate failed to address. Rather, it is a legal issue that the magistrate necessarily addressed before reaching his more specific conclusion that plaintiff had an occupational disease.
No new factual findings were required to make this legal determination.5 The WCAC noted:
There was no testimony presented in this matter to suggest that prolonged standing was unique to defendant’s business, or that moving from warm to cold temperatures in and out of the freezer, combined with the prolonged stand*740ing, was unique to defendant’s business. [1997 Mich ACO 1285, 1287.]
Thus, there was no factual support for the magistrate’s legal conclusion that the work-related disabling condition plaintiff suffered from was compensable as a § 401 occupational disease. The magistrate made no findings of fact to support the conclusion, because there was no competent, material, and substantial evidence on which to base it. In short, Layman is not implicated.
B. CONNAWAY DOES NOT PRESENT ISSUES IMPLICATING LAYMAN
In Connaway, the wcac exceeded its review function under the substantial evidence standard. It substituted its judgment for that of the magistrate by disregarding factual findings that were supported by competent, material, and substantial evidence.
No remand to the magistrate for additional findings of fact is necessary in Connaway. The record is sufficiently complete that this Court can simply reverse the decisions of the WCAC and the Court of Appeals and reinstate the findings and holding of the magistrate. Connaway offers no excuse to overrule Layman.
C. THE LAYMAN DECISION IS SOUND
The WCAC must first determine if there is competent, material, and substantial evidence on the whole record to support the magistrate’s findings. If there is, the wcac’s review ends, and the magistrate must be affirmed. MCL 418.861a(3); MSA 17.237(861a)(3); Holden, supra at 269; Goff, supra at 513. However, if *741the factual findings lack the specificity to reveal the magistrate’s -winding path through evidence subject to multiple interpretations, the WCAC must remand the matter for additional findings. Layman, supra at 508-509; Woody v Cello-Foil Products (After Remand), 450 Mich 588, 594-595; 546 NW2d 226 (1996).
Before the 1985 legislative amendment of the WDCA, the Worker’s Compensation Appeal Board reviewed magistrates’ factual findings de novo. Since then, its successor’s role has been confined to reviewing for error.
In making factual findings, a magistrate necessarily decides what evidence from an often voluminous record to believe and what to discount. That is the magistrate’s prerogative as the primary finder of fact.6 The WCAC cannot properly review a magistrate’s findings of fact unless they
*742“are sufficiently detailed so that [the commission] can separate the facts . . . found from the law . . . applied, and [determine] that conclusory findings are inadequate because [the commission] need[s] to know the path [the magistrate] has taken through the conflicting evidence, the testimony it has adopted, the standards followed and the reasoning used to reach [the] conclusion.” [Woody, supra at 594.]
“ ‘The findings of fact must include as much of the subsidiary facts as is necessary to disclose the steps by which the factfinder reached its ultimate conclusion on each factual issue. The findings should be made at a level of specificity which will disclose to the reviewing body the choices made as between competing factual premises at the critical point that controls the ultimate conclusion of fact.’ ” [Id. at 595 (brackets omitted).]
Courts cannot adequately determine whether the wcac exceeded the scope of its reviewing power and impermissibly substituted its judgment for the magistrate’s if the factual findings are incomplete.
The majority states Woody “stands for the limited proposition that the wcac cannot review a decision by a magistrate, if the magistrate’s opinion is insufficiently detailed to allow the reviewing body to separate findings of fact from legal determinations.” Ante, pp 711-712. In such a case, “the wcac [is] forced to speculate regarding the facts and the legal reasoning relied upon.” Id., p 712. Compelling the wcac to remand even in these limited circumstances conflicts with the majority’s reading of the “clear and plain” language of the statute:
The commission or a panel of the commission may remand a matter to a worker’s compensation magistrate for purposes of supplying a complete record if it is determined *743that the record is insufficient for purposes of review. [MCL 418.861a(12); MSA 17.237(861a)(12).]
Thus, to be consistent, the majority would have to overrule Woody as well. A second-hand evaluation by the WCAC of the magistrate’s factual determinations in most cases will occasion speculation. For that reason, it is preferable for the wcac to avoid independent fact finding and, where factual ambiguities exist, remand to the magistrate.
It should remand, also, when it concludes that the magistrate missed evidence, rather than made a conscious decision not to consider it because it was unpersuasive or lacked credibility. The commission should remand, rather than make its own findings of fact, given that the appellate courts may need to review the case.
Even if the standards that are in place for appellate court review of WCAC and magistrates’ decisions were confusing, I question whether the majority opinion does anything to alleviate confusion. See ante, pp 702, n 5; 695, n 1; 704, n 6. The majority should leave settled precedent undisturbed, unless it can show that less injury will result from overruling case law than from following it. Graves, supra at 481.
The majority claims Layman has caused delays, relying on the conclusory statements of a party, defendant Great Atlantic and Pacific Tea Company:
Layman’s requirement of “[r]emand for factual determination of an overlooked point slows the administrative process to a virtual standstill.” [Ante, p 713, n 10.]
However, neither A&P nor the majority has brought forward any objective data to bolster this assertion. *744Moreover, assuming there are delays, they are more than offset by the ultimate accomplishment of more accurate, hence fair, resolution of worker’s compensation cases.7
The wdca requires appellate courts to review the commission’s findings of fact under the “any evidence” standard. Case law requires appellate courts to review the commission’s assessment of the magistrates’ findings de novo, asking whether there was “substantial evidence” for the findings. Layman, supra at 507; Goff, supra at 513-514; MCL 418.861a(14); MSA 17.237(861a)(14); Cardinal Mooney High School, supra at 80. The Legislature has the prerogative to alter our settled case law’s resolution of the standards.8 See ante, pp 698-699. It is in the interest of jurisprudential stability that this Court bow to precedent and abide by its earlier resolution of the standards. To alter them now is to feed the apprehension that the standards change with the makeup of the Court.
*745ffl. THE WCAC EXCEEDED ITS REVIEWING AUTHORITY IN GONNAWAY
Competent, material, and substantial evidence supports the magistrate’s conclusion that the plaintiff never completely recovered from the November 2, 1989, injury. It also supports his conclusion that the September 4, 1990, incident was a mere recurrence of and did not contribute independently to her disability. The wcac erred in not giving these findings due deference.
Plaintiff’s testimony supports the magistrate’s conclusions. She testified that she experienced soreness and swelling in her right knee throughout her work-hardening program. She had to “ice” her knee to control these problems. Between the time that Ms. Connaway stopped work hardening at the end of July 1990 and August 16, 1990, when she resumed work “on a trial basis,” she felt her knee “decreasing again, getting weaker.” She continued to ice the knee in order to control soreness and swelling.
When she reinjured her knee, plaintiff testified that she felt “hot pain . . . kind of like what I felt before,” but that she did not experience the massive swelling that occurred after the Michigan injury. The day after she returned from the hospital, she called Christine Johnson at Hartford Insurance in Grand Rapids, Michigan, from whom she had previously received worker’s compensation. She did this because she “just figured it was the, still the same accident, I hadn’t fully recovered, so I called her, ‘Well, Christine, what do I have to do? My knee didn’t hold up . . . .’” Plaintiff testified that her current symptoms are the same as the symptoms she had between the 1989 *746Michigan injury and her return to work in August of 1990.
The magistrate found the plaintiff’s testimony credible. The testimony supports the magistrate’s conclusion that plaintiff should not have returned to work in mid-August on a trial basis, because she had not recovered from her disability. likewise, it supports the magistrate’s finding that the reinjury did not independently contribute to plaintiff’s disability. The fact that she has not returned to work since reinjuring her knee does not indicate that the second injury contributed independently to her disability. It may be that plaintiff never would have recovered from her initial disability to an extent that she could return to work.
The medical facts, established by all three experts, indicate that the New York incident was simply a reinjury and did not add to her established disability. In his deposition testimony, Dr. Coss stated that, by August 8, 1990, he felt that plaintiff had “achieved maximum benefit from the work hardening and [he] suggested a trial of work.” He was tentative, but nonetheless permitted a work trial with the understanding that Ms. Connaway “would have some increased percentage chance of reinjury or intolerance to the work demands.”
When he saw plaintiff on September 13, 1990, after the second injury, he “felt she had resprained the knee.” On October 18, 1990, Dr. Coss indicated that Ms. Connaway’s knee was more stable than he had ever seen previously. While he continued her restriction of nonparticipation in heavy industry, it was because she had failed her trial return to work. He was unable to find any objective evidence that the *747New York incident caused any further harm to her knee. The magistrate found Dr. Coss’ testimony to be credible.
In Dr. Cisek’s deposition testimony, he stated:
I did not feel that there was any . . . permanency associated with the accident of 9/4/90, I felt that that particular accident represented an aggravation of her preexisting condition ....
Dr. Cisek went on to say that the New York event would result in only temporary aggravation of her preexisting condition. The magistrate found that Dr. Cisek gave credible testimony.
Finally, Dr. Korhonen testified that plaintiff had a laterally tracking patella, a congenital anomaly, which caused plaintiffs chondromalacia. He did not indicate that any damage was caused to plaintiffs anterior cruciate ligament as a result of the September 1990 injury. The magistrate did not comment regarding the credibility of Dr. Korhonen’s testimony.
Because the magistrate’s decision is supported by competent, material, and substantial evidence, it is manifest that the WCAC exceeded its reviewing power in overturning it.
“[W]here the primary compensable injury arises out of and in the course of employment],] compensability may be extended to a subsequent injury or aggravation of the primary injury where it has been established that the subsequent injury or aggravation is the direct and natural result of the primary injury and the claimant’s own conduct has not acted as an independent intervening cause of the subsequent injury or aggravation.” [Feldbauer v Cooney Engineering Co (On Remand), 205 Mich App 284, 288; 517 *748NW2d 298 (1994), quoting Schaefer v Williamston Community Schools, 117 Mich App 26, 37; 323 NW2d 577 (1982).]
Assuming arguendo that the record supports a finding that the September 1990 injury aggravated the primary injury, plaintiffs conduct did not act as an independent intervening cause of the aggravation. The second injury was a natural result of the first. Thus, compensability is properly based on the primary injury.
In its reversal of the magistrate’s decision, the WCAC attached great significance to the fact that Dr. Cisek termed the September 1990 incident an “aggravation” of plaintiff’s prior condition. It found significant, also, that Dr. Coss noted subjective differences between plaintiff’s condition before and after the New York injury. 1997 Mich ACO 304.
The majority, likewise, relies on these details to find that the wcac’s findings of fact are supported by “any evidence.” Ante, pp 726-727. The WCAC and the majority both have failed to consider this fact: plaintiffs deterioration after the second injury is equally consistent with her testimony that her knee continuously deteriorated after she stopped work hardening, and that the second injury contributed independently to her disability. Furthermore, the fact that Dr. Cisek described plaintiff’s September 1990 incident as “an aggravation” is hardly probative of whether the incident contributed to the causation of the disability condition.
The successive injury rule states that a second injury is considered a mere recurrence of the first where “a man has suffered a back strain, followed by a period of work with continuing symptoms indicat*749ing that the original condition persists, and culminating in a second period of disability precipitated by some lift or exertion.” Dressler v Grand Rapids Die Casting Corp, 402 Mich 243, 253; 262 NW2d 629 (1978). In such a case, the carrier responsible for providing coverage for the first injury remains liable for the second. An examining medical expert could well describe the second injury as an aggravation of the first without precluding the first carrier’s liability.
The example of the man with the strained back is wholly analogous to the situation in this case. On the basis of the plaintiff’s testimony and that of the three medical experts, the magistrate was entirely justified in making the factual findings that (1) the September 1990 injury did not contribute to the underlying disability, and (2) plaintiff continued to be disabled when she was working for Welded Construction Company from August 16, 1990, until her second injury on September 4, 1990.
The wcac reinterpreted the evidence and substituted its judgment for that of the magistrate, whereas the magistrate’s findings of fact were based on competent, material, and substantial evidence. This Court should reverse the wcac under the holdings of Holden and Goff. Consequently, the Court need not reach Layman to decide Connaway. The majority has overreached the actual, pertinent issues in these cases in order to overrule a case not implicated by the issues presented.
IV. CONCLUSION
I dissent from the majority opinion, because it needlessly reaches out to overrule Goff. Goff is con*750sistent with Holden and, therefore, should be left intact.
I dissent, also, because the majority overrules Layman, although these two cases do not present issues that implicate its holding. Furthermore, the Layman holding is not erroneous. The majority’s unnecessary change in worker’s compensation law will create, rather than resolve, confusion in the state’s jurisprudence.
Finally, I dissent because the majority errs in affirming the Court of Appeals and wcac decisions in Connaway. The wcac misapprehended its administrative appellate role in reviewing the magistrate’s decision. It erred as a matter of law in substituting its own findings of fact for those of the magistrate. The magistrate’s findings were based on competent, material, and substantial evidence on the whole record.
Cavanagh, J., concurred with Kelly, J.Goff v Bil-Mar Foods, Inc (After Remand), 454 Mich 507; 563 NW2d 214 (1997).
Layman v Newkirk Electric Associates, Inc, 458 Mich 494; 581 NW2d 244 (1998).
MCL 418.101 et seq.-, MSA 17.237(101) et seq.
The “ripeness doctrine” requires courts to refrain from adjudicating issues not actually presented by the case or controversy. The doctrine counsels that courts not adjudicate an issue that is only hypothetical or speculative. Black’s Law Dictionary (6th ed), p 1328.
The majority ignores the “clear and plain meaning” of this sentence when it notes that, to the contrary, “the wcac did clearly engage here in independent fact finding.” Ante, p 718 (emphasis in original). As previously stated, Layman held that, where findings of fact necessary to support a legal conclusion are incomplete, the wcac must remand to the magistrate for the requisite fact finding. Id. at 509. Because additional findings of fact were not necessary to support the legal conclusion reached by the wcac, Layman is not implicated.
A primary purpose of [the Legislature’s 1985 amendment of the wdca] is to make the decisions of the magistrates final in most cases. -While an appeal can be filed, it is intended that relatively few appeals will be successful. The number of members of the workers’ compensation appellate tribunal has been reduced because the appellate role has been reduced from factfinder to a limited review for error. The decision of the magistrates will in most cases constitute the final decision. . . .
A magistrate, in hearing a workers’ compensation claim, will have the same role as a judge when the judge acts as trier of fact in an action brought to enforce a right created by statute. A magistrate, like a judge, will find the facts with a large measure of finality and apply the law to the facts, and in so doing will often find it necessary to construe the workers’ compensation act. . . . The findings of fact of a circuit judge are subject to reversal if clearly erroneous (when the Court of Appeals or this Court is left with the definite and firm conviction that a mistake was made), while a magistrate’s findings of fact can be reversed on appeal only if there is not substantial evidence on the whole record to support the decision. [Civil Service Comm v Dep’t of Labor, 424 Mich 571, 621-622; 384 NW2d 728 (1986).]
The majority does not claim that the decisions that appellate courts make involving the wdca are biased to reflect the result favored by a particular court. Thus, I find confusing and contradictory the irauority’s statement that, under the settled standards of review and Layman’s dictate that findings of fact should be made by the magistrate, “decisions of the appellate courts are resultantly more arbitrary and less predictable . . . .” Ante, p 694.
The majority repeatedly claims that this dissent fails to treat the wcac’s factual findings as conclusive on appellate review, in derogation of the statutory language. I reiterate that the Legislature also provided that “findings of fact made by a worker’s compensation magistrate shall be considered conclusive by the commission if supported by competent, material, and substantial evidence on the whole record.” MCL 418.861a(3); MSA 17.237(861a)(3). The legal basis on which I would reverse the wcac’s decision in Connaway is that it violated this legislative command. It failed to give the appropriate deference to the properly supported factual findings of the magistrate.