Ricigliano v. Ideal Forging Corp., 280 Conn. 723

Summary

The Supreme Court of Connecticut held that the limitations period for filing a workers’ compensation claim based on an occupational disease begins when the claimant knows or reasonably should know that the disease is causally connected to employment, rather than necessarily on the date of diagnosis. The court relied on the statutory text, legislative history, and prior decisions interpreting the phrase “first manifestation of a symptom of the occupational disease.” It reversed the Compensation Review Board’s dismissal of the plaintiff’s claim as untimely.

Holdings

1. Under General Statutes § 31-294c(a), the limitations period begins when the claimant has actual or constructive knowledge that the disease or its symptoms are causally connected to the claimant's employment, not merely when the disease is diagnosed.
2. The court owed no deference to the board's interpretation of § 31-294c and reviewed the statutory issue plenarily.

Questions Presented

1. When does the three-year limitations period under General Statutes § 31-294c(a) begin for a workers' compensation claim involving an occupational disease when the claimant has been diagnosed with the disease but does not yet know that it is causally connected to workplace exposure?
2. Whether the Workers' Compensation Review Board was entitled to deference in interpreting the phrase "first manifestation of a symptom of the occupational disease."

Disposition

reversed_and_remanded