## Facts

- Henry Ross worked about 25 years for Oxford Paper Company as a roll handler, manually moving heavy paper rolls.
- Over time, he developed progressive numbness and discomfort in his hands and repeatedly sought treatment at the company first-aid department.
- On March 17, 1974, Ross experienced total numbness and could no longer perform his work; he stopped working.
- A physician diagnosed Ross with carpal tunnel syndrome, attributed to chronic trauma from repetitive work activity.
- On October 9, 1974, Ross petitioned for workers’ compensation benefits.
- The Industrial Accident Commission awarded compensation from March 17, 1974, finding a compensable “personal injury” under the post–October 3, 1973 amendment that removed the requirement of an injury “by accident.”
- The employer and insurer appealed; the Superior Court sustained the award, and they appealed further.

## Issues

1. Whether a gradual, cumulative-trauma condition (carpal tunnel syndrome) constitutes a compensable “personal injury” under Maine’s amended workers’ compensation statute that no longer requires an injury “by accident.”
2. For a gradual injury, what date controls the statute’s applicability: onset of symptoms or the date the condition culminates in disability.
3. Whether the statutory notice requirement was satisfied where the employee was treated by the employer’s medical personnel.

## Decision

- The Supreme Judicial Court of Maine affirmed the Superior Court and sustained the Commission’s award.
- The court held that cumulative-trauma disability may qualify as a compensable “personal injury” under the amended statute even without a discrete accident.
- The court approved using March 17, 1974—the date Ross became unable to work—as the operative injury date for applying the amended law.
- The court held the notice requirement was satisfied because the company physician’s knowledge of the work-related condition was imputable to the employer.
- The court found competent evidence supporting the Commission’s causation finding and no basis to disturb it on appeal.

## Legal Principles

- After Maine removed “by accident” from the workers’ compensation statute, “personal injury” can include disability caused by gradual, repetitive, work-related trauma.
- For cumulative-trauma injuries, the relevant injury date for statutory application may be the date the condition manifests as compensable disability (loss of ability to work), not the earliest symptoms.
- An employer may be charged with notice of an employee’s work-related condition based on the knowledge of the employer’s medical personnel.
- Appellate review of workers’ compensation findings is deferential; factual determinations supported by competent evidence are upheld absent clear error.
- The workers’ compensation statute is construed liberally to effect its remedial purpose.

## Conclusion

Maine’s high court sustained compensation for carpal tunnel syndrome caused by repetitive work, treated the disability-manifestation date as the operative injury date under the amended statute, and held notice satisfied through the company physician’s knowledge imputed to the employer.


Ross v. Oxford Paper Co., 363 A.2d 712 (Me. 1976)