Titles can be misleading. So, lest the writer be accused of unfair legal merchandising, I must declare at the outset that the non-traumatic ulcer is not compensable, given the present state of the law. I cannot claim that the non-traumatic ulcer has never been held compensable. I can only asseverate that no such holding was uncovered in the course of extended examination of workmen's compensation disputes which have reached courts of review.
Carl L. Stern, Compensability of Non-Traumatic Ulcer, 14 Clev.-Marshall L. Rev. 483 (1965)