## Facts

- Three consolidated workers’ compensation claims alleged gradual-onset hand/wrist conditions from repetitive work: (1) copy editor/proofreader (carpal tunnel), (2) poultry-plant sanitation worker (carpal tunnel), and (3) poultry “rehang” worker (tenosynovitis/trigger thumbs).
- In each claim, medical evidence attributed the condition to repetitive hand motions performed at work and described the condition as a “disease,” not a discrete accidental injury.
- The Workers’ Compensation Commission awarded benefits in all three cases on an occupational-disease theory.
- The Court of Appeals affirmed, endorsing a view that a disease caused by repetitive motion may be treated as an occupational disease when supported by medical evidence.
- The employers appealed, arguing the statutory standard for an occupational disease was misapplied.

## Issues

1. Whether gradual-onset repetitive-motion conditions (carpal tunnel syndrome and tenosynovitis) qualify as compensable “occupational diseases” under the Virginia Workers’ Compensation Act.
2. Whether medical testimony that a condition is a “disease” caused by repetitive work is sufficient, without proof the disease is characteristic of and peculiar to the claimant’s employment and not an ordinary disease of life.
3. Whether the Commission and Court of Appeals committed an error of law by collapsing the statutory distinctions among injury by accident, occupational disease, and ordinary disease of life.

## Decision

- The Supreme Court of Virginia reversed the Court of Appeals in all three cases.
- The Court rejected a categorical rule equating repetitive-motion causation with an occupational disease.
- The Court held the claimants did not prove, on the records presented, that their conditions were occupational diseases within the statutory meaning.
- The compensation awards were set aside because the Commission and Court of Appeals applied an incorrect legal standard.

## Legal Principles

- An occupational disease requires more than workplace causation; it must be characteristic of and peculiar to the employment and not an ordinary disease of life to which the public is equally exposed outside the employment.
- A gradual-onset condition from repetitive activity is not transformed into an occupational disease merely because a physician labels it a “disease” and relates it to repetitive work.
- Medical testimony informs diagnosis and causation, but classification as an “occupational disease” is a legal determination governed by statute.
- Appellate deference to the Commission’s factual findings does not bar correction of legal error in applying statutory definitions.

## Conclusion

The Supreme Court of Virginia held that repetitive-motion hand conditions were not compensable as occupational diseases absent evidence that the diseases were distinctive hazards of the particular jobs, and it reversed awards that had treated repetitive-motion causation and medical labeling as sufficient.


Stenrich Grp., Inc. v. Jemmott, 251 Va. 186, 467 S.E.2d 795 (Va. 1996)