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

Case No. MISSING
Regular Panel Decision

In re Eastern District Repetitive Stress Injury Litigation

The defendants sought to transfer 78 repetitive stress injury (RSI) cases from the Eastern District of New York to districts where the claims arose, also seeking severance of individual claims. Over 450 RSI cases, involving over 1,000 plaintiffs against more than 100 equipment manufacturers, were initially consolidated in the Eastern District. However, the Second Circuit later vacated the consolidation orders, finding it an abuse of discretion due to lack of common facts and varying state laws. Relying on this guidance, the court granted transfer in 75 cases and denied it in three, citing factors such as convenience of parties and witnesses, judicial economy, and the public interest in local adjudication of local controversies. The court also ordered severance where necessary to facilitate transfer.

Transfer of VenueMultidistrict LitigationRepetitive Stress InjuryProducts LiabilityForum Non ConveniensSeverance of ClaimsConsolidation of CasesJudicial EconomyWitness ConvenienceChoice of Forum
References
16
Case No. MISSING
Regular Panel Decision
Dec 03, 2004

Claim of Scally v. Ravena Coeymans Selkirk Central School District

In this case, a claimant appealed a Workers’ Compensation Board decision regarding apportionment of her workers' compensation award. The claimant, who suffered a work-related left knee injury in 2002, had a pre-existing non-work-related injury to the same knee from 1986. While a WCLJ initially denied apportionment, the Board reversed, directing a 50/50 apportionment based on the premise that the prior injury would have resulted in a schedule loss of use award had it been work-related. The appellate court upheld the Board's determination, deferring to its interpretation that a non-work-related injury leading to a schedule loss of use constitutes a "disability in a compensation sense" for apportionment purposes. This decision was supported by medical expert testimony indicating a schedule loss of use from the prior surgery.

Workers' CompensationApportionmentKnee InjuryNon-work-related InjurySchedule Loss of UsePreexisting ConditionMedical Expert TestimonyBoard InterpretationJudicial ReviewAppellate Decision
References
13
Case No. MISSING
Regular Panel Decision

Burroughs v. Northern Telecom, Inc.

The District Court for the Eastern District of New York, in a Memorandum and Order authored by District Judge Weinstein, addressed a motion to consolidate 44 repetitive stress injury (RSI) cases, alleging conditions such as Carpal Tunnel Syndrome from computer use, before a single judge. The court granted the motion for consolidation, assigning the cases to Judge Denis R. Hurley to oversee. Simultaneously, a motion by Northern Telecom, Inc. to transfer the *Burroughs* action to the Southern District of New York was denied. The decision highlighted the importance of early consolidation and coordinated case management, drawing parallels with asbestos and DES litigations, to enhance discovery efficiency, reduce transaction costs, and ensure equitable resolution of complex mass tort cases.

Repetitive Strain InjuryRSI CasesConsolidation of ActionsMultidistrict LitigationCarpal Tunnel SyndromeJudicial EconomyMass Tort LitigationTransfer of VenueFederal Rules of Civil ProcedureEastern District of New York
References
22
Case No. 2023 NY Slip Op 00140 [212 AD3d 974]
Regular Panel Decision
Jan 12, 2023

Matter of Molnar v. JRL S. Hampton, LLC

Claimant John Molnar appealed a Workers' Compensation Board decision which disallowed his claim for occupational bilateral wrists and hands injury. The Board affirmed a Workers' Compensation Law Judge's decision, finding the claim was precluded by collateral estoppel. Molnar had a prior established claim for occupational bilateral carpal tunnel syndrome and a second claim for repetitive-use wrist injury that was disallowed by the Board in August 2020 for lack of causal relationship to employment. The Board determined that the issue of causal link between employment and repetitive-use wrist injury in the instant claim was identical to the issue previously litigated and decided against Molnar, thus applying the doctrine of collateral estoppel to preclude relitigation.

Collateral EstoppelRes JudicataOccupational DiseaseCarpal Tunnel SyndromeRepetitive-Use InjuryWorkers' Compensation BenefitsAppellate ReviewCausal RelationshipBoard DecisionClaim Disallowed
References
7
Case No. 534670
Regular Panel Decision
Jan 12, 2023

In the Matter of the Claim of John Molnar

Claimant John Molnar appealed a decision by the Workers' Compensation Board which disallowed his claim for workers' compensation benefits, alleging an occupational disease of the bilateral wrists and hands. The Board affirmed a Workers' Compensation Law Judge's finding that the instant claim was an attempt to relitigate a previously disallowed claim from August 2020. This prior claim also involved a repetitive-use injury to his bilateral wrists, where the Board found a lack of evidence for a causal link to his employment. The Appellate Division, Third Judicial Department, affirmed the Board's decision, ruling that the doctrine of collateral estoppel precluded relitigation of the identical issue concerning the causal relationship between Molnar's employment and his alleged repetitive-use injury.

Occupational DiseaseBilateral Wrist InjuriesCarpal Tunnel SyndromeRepetitive Use InjuryCollateral EstoppelRes JudicataClaim DisallowanceWorkers' Compensation AppealCausal RelationshipPrior Litigation
References
6
Case No. MISSING
Regular Panel Decision

Mancuso v. Collins

Plaintiff appealed an order from the Supreme Court, Monroe County, which had granted summary judgment to defendants John A. Camille, Todd M. Collins, Sharon R. Collins, and a fourth-party defendant in a multi-vehicle personal injury action, thereby dismissing the plaintiff's second amended complaint. The appellate court found that the defendants failed to meet their initial burden to establish that the plaintiff did not sustain a serious injury under the permanent consequential limitation of use and significant limitation of use categories of Insurance Law § 5102 [d]. The defendants' own medical submissions indicated serious injuries with objective evidence. Although the defendants met their burden regarding the 90/180 category, the plaintiff successfully raised a factual issue. Consequently, the appellate order unanimously reversed the lower court's decision, denying all motions and cross-motions, and reinstated the second amended complaint.

Personal InjuryMulti-Vehicle AccidentSummary JudgmentSerious Injury ThresholdInsurance Law 5102(d)Appellate ReversalMedical EvidenceRange of MotionObjective EvidenceSpinal Injury
References
3
Case No. ADJ9171432
Regular
Apr 25, 2016

Kenneth Evanoff vs. CITY OF LOS ANGELES, SUBSEQUENT INJURIES BENEFITS TRUST FUND

This case involves an applicant seeking reconsideration of a workers' compensation award. The applicant, previously awarded 96% permanent disability for a 2007 injury, suffered a subsequent injury in 2012 resulting in prostate cancer. The initial award used the Combined Values Chart to calculate the combined disability at 98%, entitling him to benefits from the Subsequent Injuries Benefits Trust Fund (SIBTF). The applicant argues the trial judge erred by using the Combined Values Chart and seeks to simply add the disability percentages, leading to a 100% combined disability. The Board granted reconsideration, finding that in the absence of overlapping disabilities, the disabilities should be added, entitling the applicant to a 100% permanent disability rating and remanding for a new award.

Subsequent Injuries Benefits Trust FundSIBTFCumulative Trauma InjuryPermanent DisabilityCombined Values ChartLabor Code section 4664(c)(1)(G)Whole Person ImpairmentWPIDate of InjuryDate of Knowledge
References
1
Case No. MISSING
Regular Panel Decision

Castro v. New York City Transit Authority

Claimant suffered compensable right knee injuries in 1992 and 1994, leading to a stipulated 22.5% schedule loss of use award in 2001, after which the cases were closed. Upon reopening in 2005, liability shifted from the employer's workers' compensation carrier to the Special Fund for Reopened Cases under Workers’ Compensation Law § 25-a. Following a recurrence of injuries in October 2005, the Fund sought a credit for the prior schedule loss of use award paid by the carrier, which was initially denied but later granted by the Workers’ Compensation Board. Claimant appealed this decision, arguing that the Fund should not receive credit for awards commencing more than two years prior to the transfer of liability, citing Workers’ Compensation Law § 25-a (1) and prior case law. The Appellate Division affirmed the Board's decision, explaining that the Fund assumes the carrier's rights and responsibilities, including any existing credits, and distinguished the cited precedent based on a lack of injury reclassification in the current case.

Workers' Compensation Law § 25-aSchedule Loss of Use AwardSpecial Fund for Reopened CasesCredit Against AwardsLiability TransferRecurrence of InjuryAppellate DivisionWorkers' Compensation Board DecisionStipulationCase Reopening
References
5
Case No. MISSING
Regular Panel Decision
Dec 05, 1996

Blanco v. American Telephone & Telegraph Co.

This opinion addresses numerous plaintiffs' appeals concerning repetitive stress injuries (RSI) allegedly caused by data entry keyboards, focusing on the applicable Statute of Limitations. The court determined that CPLR 214-c (the 'toxic tort' statute, which allows discovery-based accrual) does not apply to keyboard injuries because a keyboard is not a 'substance.' Instead, the traditional CPLR 214 rule applies, meaning the cause of action accrues upon the initial use of the allegedly defective keyboard, irrespective of when symptoms manifest. The decision led to the dismissal of many complaints as time-barred, while reinstating others where the first use fell within the three-year statutory period. The court acknowledged the harsh outcome and suggested legislative intervention for such unique injuries.

Repetitive Strain InjuryStatute of LimitationsProduct LiabilityToxic TortCPLR 214CPLR 214-cKeyboard InjuryAccrual of Cause of ActionDiscovery RuleAppellate Review
References
11
Case No. MISSING
Regular Panel Decision

Matter of Sanchez v. Sts Steel

The claimant appealed a Workers' Compensation Board decision from January 7, 2016, which granted a 30% Schedule Loss of Use (SLU) award for a right knee injury but applied apportionment to it. The claimant, a steel worker, sustained a work-related right knee injury in February 2007, necessitating a second arthroscopy. He had a prior nonwork-related right knee injury and surgery in 2005. The WCLJ found 66⅔% of the SLU attributable to the 2007 injury and 33⅓% to the 2005 injury. The Board upheld this apportionment. The court affirmed the Board's decision, finding it supported by substantial evidence from medical examiners that the prior nonwork-related injury, had it been compensable, would have resulted in an SLU finding.

Workers' CompensationSchedule Loss of UseApportionmentRight Knee InjuryMeniscus TearPreexisting ConditionMedical EvidenceSubstantial EvidenceAppellate ReviewWorkers' Compensation Board
References
11
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