## Facts

- Wanda Cagle worked for Peoria County Belwood Nursing Home (Belwood) for about 12 years, including roughly six years in the facility’s laundry room.
- Her laundry duties included carrying laundry bags weighing about 25–50 pounds, sorting laundry, loading large washing machines, and operating the machines.
- Operating the machines required repeated gripping and opening/closing spring-loaded washing-machine doors during each shift.
- While doing this work, Cagle began experiencing pain, numbness, and tingling in her left wrist/hand.
- By October 4, 1976, the symptoms became so severe at work that she could no longer grip the washing-machine doors during her shift.
- On October 5, 1976, Cagle saw a neurologist who related her symptoms to her work; she was diagnosed with carpal tunnel syndrome and later underwent surgery.
- Cagle continued working for a period after symptoms began and later sought benefits.
- On August 24, 1979, Cagle filed a workers’ compensation claim alleging her carpal tunnel syndrome resulted from the repetitive nature of her laundry-room work.
- The arbitrator found Cagle suffered an accidental injury on October 4, 1976 due to repeated trauma from operating the washing machines and awarded benefits (including temporary total disability and permanent partial disability).
- The Industrial Commission affirmed the award, and the circuit court confirmed the Commission’s decision.
- Belwood appealed, arguing the condition was not a compensable “accidental injury” because it was not traceable to one specific incident, and also challenged timeliness based on the claimed accident date.

## Issues

1. Whether carpal tunnel syndrome caused by repetitive workplace trauma, rather than a single identifiable mishap, qualifies as a compensable “accidental injury” under the Illinois Workers’ Compensation Act.
2. For statute-of-limitations purposes in a repetitive-trauma case, what is the proper “date of accident,” and was Cagle’s 1979 claim timely based on that date.

## Decision

- The Illinois Appellate Court affirmed the circuit court’s judgment confirming the Industrial Commission’s award.
- The court held that a work-related injury developing over time from repetitive trauma may qualify as an “accidental injury” under the Act even without proof of a single, specific incident at a definite time and place.
- The court held the claim was not time-barred because, in repetitive-trauma cases, the accident date for limitations purposes is when the injury and its work-related cause become reasonably apparent to the employee; the Commission could treat October 4, 1976 as that date on this record.
- The court declined to disturb the Commission’s causation and accident-date findings because they were supported by the evidence and therefore not against the manifest weight of the evidence.

## Legal Principles

- An “accidental injury” under the Illinois Workers’ Compensation Act can be established by the cumulative effect of repetitive workplace trauma; a sudden, isolated event is not required.
- In repetitive-trauma cases, the limitations period runs from the date when the injury and its causal connection to work would be apparent to a reasonable person in the employee’s position (a manifestation-based approach).
- The Industrial Commission’s factual determinations, including medical causation and selection of an accident date supported by the record, are upheld on review unless they are against the manifest weight of the evidence.
- In setting an accident date for repetitive trauma, the Commission may rely on the point when symptoms culminate in an inability to perform job duties, especially when closely followed by medical confirmation of a work-related condition.

## Conclusion

The appellate court upheld the Commission’s award to Cagle, ruling that repetitive-trauma carpal tunnel syndrome can be a compensable accidental injury and that the claim was timely because the accident date in such cases is when the injury and its relation to work become reasonably apparent, which the Commission could fix as October 4, 1976 based on the evidence.


Peoria County Belwood Nursing Home v. The Industrial Commission, 487 N.E.2d 356 (1985)