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Case Law Database

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 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
Jan 14, 1998

Antholzner v. Key Tronic Corp.

Plaintiffs Judith Antholzner and Richard Antholzner filed a personal injury action against several computer keyboard manufacturers and distributors, alleging cumulative trauma injury from keyboard use. Defendants moved for summary judgment, asserting the claims were barred by New York's statute of limitations. Magistrate Judge Foschio issued a Report and Recommendation, distinguishing repetitive stress injuries from toxic torts and concluding the statute of limitations begins at the first onset of symptoms, not initial exposure. District Judge Arcara adopted the Magistrate Judge's recommendation, denying the defendants' motions for summary judgment and scheduling a meeting to set a trial date.

Repetitive Stress InjuryCumulative Trauma DisorderCarpal Tunnel SyndromeStatute of LimitationsSummary Judgment MotionPersonal InjuryProduct LiabilityComputer Keyboard InjuryAccrual of Cause of ActionToxic Tort Distinction
References
16
Case No. MISSING
Regular Panel Decision

DeDivitis v. International Business Machines Corp.

Plaintiff, a former New York Telephone Company employee, developed bilateral carpal tunnel syndrome from using a keyboard manufactured by the defendant. She initiated legal action against the defendant, alleging negligence and strict product liability. The plaintiff sought discovery of workers' compensation claims and OSHA 200 logs related to repetitive motion injuries caused by the defendant's keyboards. The Supreme Court initially denied the plaintiff's discovery motion and granted the defendant's protective order. On appeal, the court modified the Supreme Court's order, partially granting the plaintiff's motion and allowing limited discovery of relevant workers' compensation records and OSHA 200 logs, subject to specific conditions and redactions.

Product LiabilityNegligenceDiscovery DisputeWorkers' Compensation RecordsOSHA 200 LogsRepetitive Motion InjuryCarpal Tunnel SyndromeKeyboard InjuryEvidence AdmissibilityScope of Discovery
References
13
Case No. MISSING
Regular Panel Decision

Kuechler v. 805 Middlesex Corp.

Plaintiffs Roger E. Kuechler, L. Cris Collingwood, and Edward Foehlinger filed a diversity suit against 805 Middlesex and Eastman Kodak, alleging personal injuries from keyboard equipment, with Foehlinger claiming loss of consortium. Defendants moved to dismiss based on the statute of limitations. The court, applying New York law, determined that the three-year statute of limitations applies from the time of injury and that the discovery rule under N.Y.C.P.L.R. § 214-c does not apply to repetitive stress injuries from keyboard use. While a single condition doesn't create multiple injuries, qualitatively different injuries occurring within the statutory period could sustain claims. The court conditionally granted the motion to dismiss, allowing plaintiffs 45 days to file an amended complaint alleging such qualitatively different injuries within the statutory period.

Repetitive Strain InjuryStatute of LimitationsProduct LiabilityKeyboard InjuryDiversity JurisdictionMotion to DismissDiscovery RulePersonal InjuryLoss of ConsortiumNew York Civil Practice Law and Rules
References
7
Case No. MISSING
Regular Panel Decision
Sep 10, 1997

Reese v. Key Tronic Corp.

Zorena A. Reese filed a diversity action against Ontel Corporation, Key Tronic Corporation, and Lockheed Corporation, alleging personal injuries from using an Ontel keyboard during her employment at New York Telephone Company. She claims to have suffered cumulative trauma injuries (bilateral median nerve entrapment and carpal tunnel syndrome) with symptoms appearing in mid-1990. Defendants moved for summary judgment, arguing her claims were time-barred by the three-year statute of limitations, contending the period began with her first exposure to the keyboard. The Magistrate Judge recommended denying the defendants' motions, distinguishing repetitive stress injuries from toxic torts and stating that the statute of limitations commences upon the first onset of symptoms. The District Court adopted this recommendation, denying the motions and noting a genuine issue of material fact regarding the exact onset date of plaintiff's symptoms.

Repetitive Stress InjuryCarpal Tunnel SyndromeStatute of LimitationsSummary JudgmentAccrual DateToxic Tort DistinctionProduct LiabilityComputer Keyboard InjuryPersonal InjuryDiversity Jurisdiction
References
16
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. MISSING
Regular Panel Decision

Evans v. Key Tronic Corp.

Plaintiff Maureen Evans sued White Pine Software, Visual T.I., Inc., Ontel Corporation, Key Tronic Corporation, Visual Technology Incorporated, and Lockheed Corporation, alleging personal injuries from using a defective computer keyboard during her employment. Defendants moved for summary judgment, arguing her claims were barred by the statute of limitations. Magistrate Judge Foschio recommended denying the motions, concluding that for repetitive stress injuries, the three-year statute of limitations commences upon the first onset of symptoms, not the first use of the product. Since Evans experienced symptoms in December 1992 and filed suit in May 1995, her complaint was timely. District Judge Arcara adopted the Report and Recommendation, thereby denying defendants' motions for summary judgment.

Repetitive Stress InjuryCarpal Tunnel SyndromeStatute of LimitationsSummary JudgmentProduct LiabilityAccrual of Cause of ActionNew York Civil Practice Law and RulesFederal JurisdictionToxic Tort DistinctionComputer Keyboard Injury
References
16
Case No. MISSING
Regular Panel Decision
Jul 17, 2001

Claim of Jones v. HSBC

The case involves an appeal from a Workers’ Compensation Board decision concerning the applicability of Workers’ Compensation Law § 25-a. The claimant, an accounts clerk for Marine Midland Bank, developed carpal tunnel syndrome from repetitive keyboarding in 1991, leading to an occupational disease claim. After surgery in 1994, the case was closed in 1995 with an award for a 15% schedule loss of use of her right hand. Subsequently, the claimant experienced increased pain and new bilateral diagnoses in 1998, prompting a new claim and modification of the original claim to include additional body parts. The central dispute was whether the Special Fund for Reopened Cases was responsible for further medical payments. The Board affirmed that § 25-a applied, holding the Fund liable for treatment after September 11, 1998. The appellate court affirmed the Board's decision, finding its determination that the case was truly closed in 1995 and subsequently reopened was supported by substantial evidence.

Workers' Compensation Law § 25-aSpecial Fund for Reopened CasesCase Reopening CriteriaOccupational Disease ClaimCarpal Tunnel SyndromeRepetitive Motion InjurySchedule Loss of Use AwardMedical Payments ResponsibilityAppellate Division AffirmanceSubstantial Evidence Review
References
13
Case No. MISSING
Regular Panel Decision

Clanton v. Salon Visentin, Inc.

Claimant, a former shampooer and full-time receptionist, developed bilateral carpal tunnel syndrome and right epicondylitis. She sought workers' compensation benefits, claiming her injuries were an occupational disease due to strenuous repetitive movements associated with her employment. A Workers’ Compensation Law Judge and subsequently the Workers’ Compensation Board denied her claim, finding insufficient evidence of a recognizable link between her condition and a distinctive feature of her occupation. The appellate court affirmed the Board's determination, concluding that the record supported the finding that there was insufficient evidence of a specific repetitive movement suggesting a link between her job and injuries.

Occupational diseaseCarpal Tunnel SyndromeEpicondylitisRepetitive motion injuryWorkers' compensation benefitsCausal relationshipMedical evidenceSufficiency of evidenceAppellate reviewBoard decision
References
3
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