Stenrich Group v. Jemmott

467 S.E.2d 795, 251 Va. 186 (1996)

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Stenrich Group v. Jemmott

Virginia Supreme Court
467 S.E.2d 795, 251 Va. 186 (1996)

Facts

In 1989 Claudia Jemmott (plaintiff) started working for the Stenrich Group, Inc. (Stenrich) (defendant) as a copy editor and proofreader. Jemmott’s duties included repetitive motion with her hands. In August 1992, a doctor diagnosed Jemmott with carpal tunnel syndrome, which he classified as a disease resulting from repetitive motions involved in her work. The Workers’ Compensation Commission (the commission) awarded workers’-compensation benefits to Jemmott, finding that the doctor’s testimony established that carpal tunnel syndrome was a disease, not an injury. In 1990 Linda Kay Martin (plaintiff) started working for Purdue Farms, Inc. (defendant) as a sanitation worker. Martin’s duties involved repetitive use of her hands. In October 1992, the plant nurse referred Martin to an orthopedic surgeon, who diagnosed Martin with carpal tunnel syndrome resulting from repetitive use of her hands during work. The surgeon found that Martin suffered from a disease, not an injury. The commission awarded benefits to Martin and found that it had been consistently held that a disease caused by repetitive motion is an occupational disease, compensable if supported by medical evidence. In 1993 Shirley Biller (plaintiff) started working for Wampler-Longacre Chicken, Inc. (Wampler-Longacre) (defendant) in the rehang department of its processing plant. Biller’s duties required the repetitive use of both of her hands. In November 1993, Biller saw a doctor, who diagnosed Biller with tenosynovitis, sometimes called trigger thumbs, resulting from repetitive minor injuries to her thumbs during work. The commission awarded benefits to Biller, finding that Biller suffered from a disease caused by work repetition. The court of appeals in each case affirmed the commission’s holdings, finding that each claimant suffered from an occupational disease under the Workers’ Compensation Act. Stenrich, Perdue Farms, and Wampler-Longacre appealed.

Rule of Law

Issue

Holding and Reasoning (Carrico, C.J.)

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