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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 2017-05-0061
Regular Panel Decision
Jan 29, 2019

Reed, Anthony v. Nissan N.A., Inc.

Mr. Anthony Reed, an employee of Nissan N.A., Inc., filed a workers' compensation claim for bilateral carpal tunnel syndrome and a work-related injury to his right cubital tunnel. The court conducted a compensation hearing to determine the impairment rating and the compensability of the cubital tunnel syndrome. The court gave more weight to Dr. Jeffrey Hazlewood's impairment rating of three percent to the body as a whole, rather than Dr. S. R. Brown's. Additionally, the court found that Mr. Reed proved his right cubital tunnel injury was work-related and ordered Nissan to cover the treatment by Dr. S. R. Brown for both conditions. Nissan was also ordered to pay a lump sum of $11,998 for vocational disability.

Carpal Tunnel SyndromeCubital Tunnel SyndromeImpairment Rating DisputeMedical Evaluation WeightTreating Physician AppointmentVocational Disability AwardElectrodiagnostic TestingAMA Guides Sixth EditionUpper Extremity InjuryWork-Related Injury
References
4
Case No. 2019 NY Slip Op 06836
Regular Panel Decision
Sep 26, 2019

Matter of Christensen-Mavrigiannakis v. Nomura Sec. Intl., Inc.

Claimant Deborah Christensen-Mavrigiannakis sustained a workplace injury from a fall, initially establishing claims for neck and back injuries. The Workers' Compensation Board (WCB) later amended the claim to include a left shoulder injury and subsequently bilateral carpal tunnel syndrome and right cubital tunnel syndrome, along with awards at a temporary total disability rate. On appeal, the Appellate Division affirmed the WCB's decision regarding the left shoulder injury, citing substantial evidence based on the treating physician's testimony. However, the court reversed the WCB's amendment for the carpal tunnel and cubital tunnel syndromes, finding the medical opinion supporting causal relationship irrational. The Appellate Division upheld the WCB's finding of total disability and associated awards, acknowledging the Board's authority to modify prior decisions.

Workers' CompensationCausal RelationshipMedical EvidenceLeft Shoulder InjuryCarpal Tunnel SyndromeCubital Tunnel SyndromeIndependent Medical Examination (IME)Workers' Compensation Board (WCB)Appellate ReviewSubstantial Evidence
References
12
Case No. MISSING
Regular Panel Decision

Barnett v. Milan Seating Systems

Frances Barnett, an employee of Milan Seating Systems, suffered bilateral carpal tunnel syndrome, leading to two workers' compensation lawsuits. The first settled a left-hand injury, while the second sought compensation for a right-hand carpal tunnel and a cubital tunnel injury. A key issue on appeal was whether Barnett was still employed by her "pre-injury employer" after Milan Seating was sold to Kongsberg Automotive, which impacted the application of a 1.5 multiplier to her benefits. The court reversed the chancery court's decision, ruling that a company sale means an employee is no longer with the pre-injury employer, thus lifting the 1.5 multiplier cap for the cubital tunnel injury. However, the appellate court affirmed the chancery court's finding that the right carpal tunnel injury was not new, and further compensation was barred by res judicata. The case was remanded for vocational disability determination regarding the cubital tunnel injury without the multiplier limitation.

Workers' CompensationCarpal Tunnel SyndromeCubital Tunnel SyndromePre-Injury EmployerStatutory InterpretationRes JudicataPermanent Partial ImpairmentVocational DisabilityCompany SaleMultiplier Cap
References
14
Case No. CV-24-1279
Regular Panel Decision
Dec 11, 2025

In the Matter of the Claim of Michael Howard

Claimant Michael Howard appealed a Workers' Compensation Board decision denying his request to amend his claim to include bilateral carpal tunnel syndrome. Howard sustained multiple injuries in a 2018 assault, and his claim was later amended for various conditions. His treating physician, Ranga Krishna, diagnosed bilateral carpal tunnel syndrome in 2021, linking it to the 2018 accident. However, the carrier's consultant found a bilateral wrist sprain but no causally related carpal tunnel syndrome after examinations in 2021 and 2023, citing a lack of corroborative clinical findings despite EMG results. Both the Workers' Compensation Law Judge and the Board credited the carrier's consultant, denying the amendment due to insufficient credible evidence of causation. The Appellate Division affirmed the Board's decision, deferring to its factual determinations and assessments of medical witness credibility, which were supported by substantial evidence.

Carpal Tunnel SyndromeCausation DisputeMedical Opinion ConflictCredibility of Medical WitnessesSubstantial Evidence ReviewWorkers' Compensation Board AffirmanceClaim Amendment DenialBilateral Wrist InjuryElectromyography FindingsAppellant Burden of Proof
References
8
Case No. 524328
Regular Panel Decision
Jan 11, 2018

Matter of Murrah v. Jain Irrigation, Inc.

Claimant Steven Murrah sustained a work-related injury to his right shoulder in 2010 while working for Jain Irrigation, Inc., leading to workers' compensation benefits. In 2014, while working for a different employer, he jarred his right shoulder again. A Workers' Compensation Law Judge initially found ulnar neuritis and cubital tunnel syndrome causally related to the 2010 incident. The Workers' Compensation Board modified this, finding no causal relation for ulnar neuritis but affirming and amending the 2010 claim to include right cubital tunnel syndrome. Jain Irrigation and its carrier appealed, arguing that ulnar neuritis and cubital tunnel syndrome are the same condition and that the issue was not properly preserved. The Appellate Division, Third Department, affirmed the Board's decision, declining to take judicial notice of the conditions' synonymity due to conflicting record evidence and deferring to the Board's resolution of medical evidence.

Workers' CompensationRight Shoulder InjuryRotator CuffUlnar NeuritisCubital Tunnel SyndromeCausationMedical EvidenceAppellate ReviewJudicial NoticeWork-Related Injury
References
8
Case No. 2021-05-0344
Regular Panel Decision
May 02, 2022

Wilson, Scott v. American Paper & Twine Co.

The Court held an Expedited Hearing to determine if Mr. Wilson was entitled to medical treatment for carpal/cubital tunnel syndrome, which he alleged was a natural consequence of a compensable left-shoulder injury and subsequent rotator cuff repair surgery. Initially, Dr. Shaffer opined the condition was not attributable to the work injury. However, Dr. Paul Abbey, a hand specialist, diagnosed both carpal and cubital tunnel syndrome, stating it resulted from the prior rotator cuff surgery and was a contributing factor. Applying the 'direct and natural consequences rule,' the Court found Mr. Wilson's carpal/cubital tunnel syndrome was likely a natural consequence of his primary compensable shoulder injury, despite Dr. Abbey's inability to state it was greater than fifty percent responsible. Consequently, the Court granted benefits, ordering American Paper to continue providing medical treatment, including treatment with Dr. Abbey.

References
2
Case No. MISSING
Regular Panel Decision

Matter of Scuderi v. Mazzco Enterprises

Claimant, a union carpenter, filed a workers' compensation claim in 2010 for bilateral carpal tunnel syndrome, which was deemed an occupational disease with a disability onset of June 25, 2010. The workers’ compensation carrier for his last employer, Mazzco Enterprises, sought to apportion liability among claimant’s previous employers, including JD Consulting LLC. The Workers’ Compensation Board ultimately determined the disease was contracted on August 14, 1998, and assigned 45% of the liability to JD Consulting and its carrier. JD Consulting and its carrier appealed, contending that the Board's selection of the contraction date lacked substantial evidentiary support, as the claimant could not recall the onset of symptoms and his treating physician provided no definitive opinion on the matter. The Appellate Division concurred, reversing the Board's decision and remitting the case for further proceedings due to the insufficient evidence supporting the chosen date of contraction.

Workers' CompensationOccupational DiseaseCarpal Tunnel SyndromeApportionment of LiabilityEmployer LiabilitySubstantial EvidenceAppellate ReviewReversalRemittalNew York Law
References
8
Case No. MISSING
Regular Panel Decision
Oct 04, 2006

Claim of McKenzie v. UJA-FED

Claimant, employed in data entry, developed bilateral carpal tunnel syndrome and sought workers' compensation benefits. The Workers' Compensation Law Judge initially dismissed the claim, but the Workers' Compensation Board reversed, finding the condition to be an occupational disease causally related to employment, based on agreement between the treating physician and an independent medical examiner, and the carrier's failure to request cross-examination. The carrier appealed, arguing the Board erred in its finding regarding cross-examination and mischaracterized medical evidence. The appellate court affirmed the Board's decision, ruling that the carrier waived its right to cross-examination by not making a timely request and finding no basis to disturb the Board's assessment of the medical evidence.

Occupational DiseaseCarpal Tunnel SyndromeWorkers' CompensationMedical EvidenceCross-Examination WaiverAppellate ReviewCausationEmployment-Related InjuryMedical Expert TestimonyBoard Decision Appeal
References
6
Case No. 535366
Regular Panel Decision
Apr 13, 2023

In the Matter of the Claim of Glen Delaney

Claimant Glen Delaney filed a workers' compensation claim for bilateral arm and hand injuries diagnosed as neuropathy, osteoarthritis, bilateral carpal tunnel, and right cubital tunnel syndrome, attributed to a work-related occupational disease as a construction laborer. The Workers' Compensation Board established December 19, 2018, as the date of disablement, holding John P. Picone, Inc., as the employer at that time, and Starr Indemnity & Liability Company as the liable carrier. Picone and Starr Indemnity appealed, challenging the disablement date and arguing Jett Industries Inc. should be the liable employer under Workers' Compensation Law § 44. The Appellate Division, Third Judicial Department, affirmed the Board's decision, finding substantial evidence supported the chosen disablement date and clarifying that Workers' Compensation Law § 44 dictates liability for the employer at or preceding the disablement date. The Court also upheld the WCLJ's preclusion of untimely cross-examination of physicians by the appellants.

Occupational DiseaseCarpal Tunnel SyndromeCubital Tunnel SyndromeDate of DisablementLast Employer LiabilityWorkers' Compensation Board DecisionAppellate ReviewInsurance Carrier LiabilityIME Report PreclusionRepetitive Stress Injury
References
25
Case No. 2017-06-0671
Regular Panel Decision
Jul 06, 2018

Blake, Jean v. Hendrickson USA, LLC

The Court convened an expedited hearing to determine if Hendrickson USA, LLC, should provide Jean Blake additional medical treatment under a prior settlement's open medicals clause for a February 3, 2016 work injury to her right shoulder and neck. Ms. Blake sought an independent medical exam and further treatment for her shoulder, neck, and newly raised carpal tunnel/cubital tunnel syndrome. The Court denied her request, finding that her authorized physicians had not ordered further treatment for the work-related injuries covered by the settlement. It also concluded that the cubital tunnel syndrome was unrelated to the settled workplace injury and not covered by the agreement, but noted she could file a new claim for it.

Expedited HearingMedical BenefitsWorkers' CompensationSettlement AgreementOpen MedicalsShoulder InjuryNeck InjuryCubital Tunnel SyndromeCausationPhysician's Opinion
References
1
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