A filing deadline, not a medical finding, ended a certified nursing assistant's workers' compensation claim.
Connecticut's Appellate Court on August 25, 2026 affirmed the denial of benefits to a certified nursing assistant who blamed years of patient lifting for her worn-out left hip. The court did not decide whether her injuries were real. The case turned on timing.
In Connecticut, the injury type sets the clock. Accidental injuries and repetitive trauma claims carry a one-year filing deadline. Occupational disease claims get three years. The claimant filed late, so her case survived only if her hip osteoarthritis qualified as an occupational disease.
The governing statute, General Statutes § 31-294c (a), bars any claim unless notice is given "within one year from the date of the accident or within three years from the first manifestation of a symptom of the occupational disease, as the case may be."
To reach the three-year window, she had to satisfy § 31-275 (15), which covers "any disease peculiar to the occupation in which the employee was engaged and due to causes in excess of the ordinary hazards of employment as such."
She could not. The administrative law judge found her injuries "more closely resemble[d] . . . repetitive trauma injur[ies]," which fall under the one-year rule. The claimant testified that her role was "a manual laborer job," that patients "can be up to 200 pounds," and that she was "physically taking my hands 66 percent of the shift." The judge found she "failed to prove that her alleged injuries were peculiar or more likely to be caused by her occupation as a certified nursing assistant than would other kinds of manual labor employment."
Her medical evidence did not settle it. Physicians at Yale Occupational and Environmental Medicine called the injuries work-related, and one report described the exposure as "acute." A defense expert from UConn Health called the injuries degenerative and unrelated to her work. The board noted that no report said her job made her "more susceptible" to injury. Work-related, the court made clear, is not the same as occupational disease.
The claimant filed eight notices of claim between January 2020 and November 2022 for injuries dated from October 2017 to February 2020. iCare Health Management and its insurer, Memic Indemnity Company, contested every one. Because the injuries counted as repetitive trauma, the one-year clock ran from her last day of exposure, and all eight were untimely. The commission lacked jurisdiction, and the court affirmed.
