Peoria County Belwood Nursing Home v. The Industrial Commission
138 Ill.App.3d 880 (1985)

Facts:

  • Wanda Cagle worked in the laundry room at Belwood for six years prior to her injury. She was at Belwood for a total of 12 years.
  • She started feeling some pain, numbness and tingling in her wrist around October 4, 1976.
  • On October 5th she went to the doctor, and eventually had surgery in August of 1977 for carpal tunnel syndrome (she continued to work during this time).
  • Wanda then filed a claim for compensation on August 24, 1979 alleging that she developed carpal tunnel syndrome in the course of her job.
    • The employer argued that because there was no specific incident by which the claimant’s injury could be traced to a definite time, place and cause, the injury was not an “accidental injury” under the Act.

History:

  • The arbitrator awarded benefits for temporary total disability and for 25% permanent total disability.
  • The Industrial Commission affirmed the award.
    • The arbitrator and Commission found that the claimant had sustained an accidental injury as a result of repeated trauma to her wrist in operating the two large washing machines.
  • The circuit court of Peoria County confirmed the Commission’s decision.

Issues:
(1) Whether an injury sustained as the result of work-related repetitive trauma is compensable under the Workers’ Compensation Act absent one precise, identifiable incident which a court may label an “accident.”
(2) Whether the claim was barred by the statute of limitations.

Holdings:
(1) Yes.
(2) Yes.

Reasoning:

  • (1) The rule in place at the time was that an injury was “accidental” within the meaning of the Act if it is traceable to a definite time, place and cause.
    • The court felt that it was time to do away with this narrow and harsh interpretation and adopt something that would better reflect the purpose of the Act.
  • Thus, the new rule is that an employee may be “accidentally injured” under the Act as the result of repetitive, work-related trauma even absent a final, identifiable episode of collapse.
    • Note, however, that a claimant must still fulfill his obligation of proof and show that his injury is work-related and NOT the product of the aging process.
  • (2) “We…find that where an employee…suffers a work-related injury due to repeated trauma, the date of the accidental injury is the date on which the injury ‘manifests’ itself. Manifest means to show plainly or make palpably evident.”
    • Here, that date was October 4, 1976. Since she filed the claim on August 24, 1979, she was within the three-year SOL.

Rule: An employee may be “accidentally injured” under the Act as the result of repetitive, work-related trauma even absent a final, identifiable episode of collapse.