## Facts

- Wanda J. Cagle worked for Peoria County Belwood Nursing Home for about 12 years, including six years in the laundry room.
- Her work required carrying laundry bags weighing about 25–50 pounds and loading two industrial washing machines with three compartments each.
- Loading required frequent, forceful gripping and pulling to open and close spring-loaded doors.
- By early October 1976, Cagle experienced increasing pain, numbness, and tingling in her left arm and hand and reported difficulty gripping the machine doors.
- She consulted a neurologist in October 1976; medical evidence linking her condition to work was uncontroverted.
- Cagle continued working until August 23, 1977, when she underwent surgery for carpal tunnel syndrome.
- She filed a workers’ compensation application on August 24, 1979.
- The arbitrator found an accidental injury arising out of and in the course of employment from repeated trauma, awarded temporary total disability benefits and 25% permanent partial disability (person as a whole), and set the accident date as October 4, 1976 (amended from October 5, 1976).
- The Industrial Commission affirmed; the circuit court and appellate court confirmed; the Illinois Supreme Court allowed appeal.

## Issues

1. Whether a work-related injury caused by repetitive trauma can qualify as an “accidental injury” under the Illinois Workers’ Compensation Act absent a single identifiable incident traceable to a definite time, place, and cause.
2. In repetitive-trauma cases, what date constitutes the “date of accident” for limitations purposes, and whether Cagle’s claim was time-barred.

## Decision

- The Illinois Supreme Court affirmed the appellate court and upheld the award.
- The court held that repetitive trauma can constitute a compensable accidental injury under the Act even without a single sudden event.
- The court adopted a manifestation-based rule for limitations: the accident date is when the injury and its work-related nature become apparent to a reasonable person.
- Using October 4, 1976 as the manifestation date, Cagle’s August 24, 1979 filing was within the three-year limitations period.
- The court declined to disturb the Commission’s causation and disability findings because they were supported by the record and not against the manifest weight of the evidence.

## Legal Principles

- An “accidental injury” under the Illinois Workers’ Compensation Act includes injuries caused by cumulative or repetitive work-related trauma, not only injuries tied to a single, sudden occurrence.
- For repetitive-trauma injuries, the “date of accident” for limitations purposes is the date of manifestation—when a reasonable person would recognize the injury and its causal connection to employment.
- Industrial Commission findings on causation and extent of disability are reviewed deferentially and will not be overturned unless against the manifest weight of the evidence.

## Conclusion

The court recognized cumulative trauma (including carpal tunnel syndrome) as compensable without proof of a discrete accident and fixed timeliness in such cases to a manifestation-based accident date, making Cagle’s claim timely and supporting the Commission’s benefit award.


Peoria Cnty. Belwood Nursing Home v. Indus. Comm'n, 115 Ill. 2d 524, 505 N.E.2d 1026 (Ill. 1987)