A station agent with the New York Transit Authority can’t collect workers’ compensation for carpal tunnel syndrome despite having expert testimony from her doctor.
The station agent couldn’t prove to a New York appeals court that her occupational disease was caused by a “distinctive feature of her employment.”
Change in job duties results in more time typing
Brenda Sanchez was a railroad clerk for the New York Transit Authority until 1995, when she became a station agent. Prior to 1995, her job duties included:
- manual tasks and maintenance at transit turnstiles
- heavy lifting, and
- protracted coin and token handling and counting.
After 1995, the New York Transit Authority adopted the MetroCard system, causing a change in duties for Sanchez. Her primary task became adding money to MetroCards for passengers while manning a booth.
Although the position still required some currency and coin counting, her regular tasks mostly required her use of a keyboard and typing. This led to the development of pain in her wrists.
Sanchez sought medical treatment for her worsening wrist symptoms in February 2020. Her doctor diagnosed work-related carpal tunnel syndrome, leading Sanchez to file a workers’ compensation claim in October 2020.
The New York Transit Authority contested the claim.
Judge found doctor’s testimony unconvincing
In court before a workers’ compensation law judge, Sanchez and her doctor testified regarding her job duties and how they had impacted her wrists.
Specifically, the doctor testified that, based on her exams of Sanchez and her reported work history, she felt Sanchez had the work-related occupational disease of bilateral carpal tunnel syndrome.
Despite the doctor’s assertions, the judge found there was no causal relationship between the work Sanchez was doing and her carpal tunnel syndrome.
The judge found that the doctor, while aware of Sanchez’s job duties after her role changed upon adoption of the MetroCard system, didn’t have a detailed understanding of those duties or the relationship between her more recent duties and her condition.
Although the doctor could recount all the various manual tasks Sanchez performed until 1995, she didn’t offer an explanation on how the tasks Sanchez no longer performed contributed to a medical condition first diagnosed in 2020.
The New York Workers’ Compensation Board affirmed the judge’s decision, finding that Sanchez had failed to prove a causal link between her disease and a distinctive feature of her employment.
Her claim didn’t fit definition of ‘occupational disease’
On appeal, the court agreed with the judge’s decision, finding that based on the definition of an occupational disease, Sanchez failed to successfully link her carpal tunnel syndrome to her job.
Under state law, an occupational disease is “a disease resulting from the nature of the employment and contracted therein.”
An occupational disease “does not derive from a specific condition peculiar to an employee’s place of work, nor from an environmental condition specific to the place of work.” Rather, it must be shown to have a “recognizable link between” the worker’s condition and a “distinctive feature” of their employment.
Because the denial of benefits was supported by substantial evidence, the court upheld the judge’s decision.
