Rutledge v. Tultex Corp./Kings Yarn

Margaret Rutledge (plaintiff), a habitual cigarette smoker, began working in textile mills in 1953. Rutledge worked for three mills before starting a job at a mill operated by Tultex Corp./Kings Yarn (Kings) (defendant) in 1976. The mills where Rutledge worked all had cotton dust, but Kings’ mill had less dust than the other mills. In 1969 or 1970, Rutledge developed a cough at work. The cough progressed into shortness of breath, which became severe while Rutledge was working at Kings. Rutledge was diagnosed with chronic obstructive pulmonary disease (COPD) with emphysema and chronic bronchitis. Rutledge sought workers’-compensation benefits from Kings, alleging that Kings was the employer in whose employment she was last injuriously exposed to cotton dust. Rutledge’s doctor testified before a deputy commissioner that Rutledge’s COPD was caused by both Rutledge’s exposure to cotton dust and her smoking. The doctor also testified that textile workers are at increased risk for COPD and that, although Rutledge was already suffering from pulmonary disease when she started at Kings, any exposure to cotton dust at Kings could have aggravated her condition. The deputy commissioner denied Rutledge’s claim for benefits. The commissioner said that Rutledge was showing symptoms of COPD before she started working at Kings, and any exposure to harmful cotton dust at Kings neither caused nor significantly contributed to her disease. The industrial commission adopted the commissioner’s findings, and an appellate court affirmed. The court held that the commission erred in requiring Rutledge to prove that her cotton-dust exposure at Kings caused or significantly contributed to her COPD. However, the court concluded that this error was harmless because there was no evidence that Rutledge’s COPD was an occupational disease. Rutledge appealed to the North Carolina Supreme Court.