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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

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. 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. ADJ1812869 (SAC 0356491)
Regular
Nov 10, 2010

DIVINA EMANO vs. UC DAVIS MEDICAL CENTER; Permissibly Self-Insured, Adjusted by SEDGWICK, CMS

This case involves applicant Divina Emano claiming a left carpal tunnel injury against UC Davis Medical Center. The Workers' Compensation Appeals Board granted reconsideration and amended the previous decision. Specifically, Finding of Fact No. 8 was modified to clarify that while no further treatment is needed for the left carpal tunnel injury, other industrial injuries will require reasonable and necessary medical treatment. The Board expressed surprise at the defendant's contention regarding the carpal tunnel injury, noting their prior stipulation and a relevant physician's report.

WORKERS' COMPENSATION APPEALS BOARDDIVINA EMANOUC DAVIS MEDICAL CENTERSEDGWICK CMSOPINION AND ORDERGRANTING RECONSIDERATIONDECISION AFTER RECONSIDERATIONleft carpal tunnel injuryindustrial injuriesWCJ report
References
0
Case No. 2020-07-0349
Regular Panel Decision
Jun 01, 2023

Lucia, Jr., Carlton v. DSV Solutions, Inc.

Carlton Lucia, Jr. sustained a right hand injury while working for DSV Solutions, Inc. on June 10, 2021. After initial surgery for a scaphoid fracture, he developed carpal tunnel syndrome, which Dr. Michael Dolan linked to the work injury and subsequent treatment. DSV Solutions, Inc. denied authorization for carpal tunnel release surgery, prompting an expedited hearing. The Court found Mr. Lucia's testimony credible and determined that his carpal tunnel syndrome was a direct and natural consequence of his work injury, thus granting his request for medical benefits to cover the surgery.

Right Hand InjuryCarpal Tunnel SyndromeScaphoid FractureMedical BenefitsExpedited HearingCausationAggravation of InjuryMedical Treatment AuthorizationWorkers' CompensationOrthopedics
References
5
Case No. MISSING
Regular Panel Decision
Dec 26, 2013

Claim of Hunter v. Tops Market, Inc.

The case involves an appeal concerning the transfer of liability to the Special Fund for Reopened Cases under Workers’ Compensation Law § 25-a. The claimant had an established workers' compensation claim for right carpal tunnel syndrome, with a later diagnosis of left carpal tunnel syndrome. Despite a 10% schedule loss of use for the right hand, the employer's request to transfer liability was denied by the Workers' Compensation Board. The Board ruled that the case was never truly closed because issues regarding the left carpal tunnel syndrome remained unresolved, as evidenced by a doctor's report. The Appellate Division affirmed this decision, concluding that substantial evidence supported the finding that further compensation proceedings were still contemplated, thereby preventing the transfer of liability.

Workers' Compensation Law § 25-aSpecial Fund for Reopened CasesCarpal Tunnel SyndromeOccupational DiseaseSchedule Loss of UseTransfer of LiabilityCase ClosureBoard Decision AffirmedAppellate DivisionNerve Conduction Study
References
7
Case No. 535283
Regular Panel Decision
Dec 14, 2023

In the Matter of the Claim of Racheal Brown

Claimant Racheal L. Brown, a phlebotomist, appealed two decisions by the Workers' Compensation Board. Initially, her claim for right wrist tendonitis was established as an occupational disease, but right carpal tunnel syndrome was disallowed. Claimant later sought to amend her claim to include consequential right carpal tunnel syndrome after surgery, which the WCLJ initially allowed but the Board subsequently disallowed. The Board also deemed her rebuttal application deficient. This appellate court affirmed the Board's decision, finding no abuse of discretion in rejecting the rebuttal for incompleteness and concluding that substantial evidence supported the Board's denial of the consequential carpal tunnel syndrome claim, as claimant failed to establish a causal connection by competent medical evidence. The court also affirmed the Board's modification of the degree of disability to mild, based on established conditions.

Workers' CompensationOccupational DiseaseCarpal Tunnel SyndromeRight Wrist TendonitisCausal RelationshipAppellate ReviewBoard DecisionsDisability RateMedical EvidenceAdministrative Review
References
7
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. 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. 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
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