What Do You Think?
To obtain workers’ compensation benefits for a repetitive trauma, an employee must show that his job caused the trauma. This generally requires evidence from medical records and records of the duties the worker actually performed. A recent Illinois case involving a college janitor examines what it takes to connect a gradually developing back condition to workplace activities.
The janitor’s regular duties included sweeping, vacuuming, moving furniture, stripping and waxing floors, and operating cleaning equipment. His workload intensified, he said, when the pandemic emptied the campus in March 2020. With students gone, janitors could tackle major projects continuously instead of waiting for school breaks, he said. He described lifting heavy furniture, pushing equipment, and repeatedly bending and carrying objects. He filed a workers’ compensation claim based on a repetitive trauma injury.
According to the janitor, he began experiencing lower back pain around March 2020. The pain worsened. By May 2021, he was diagnosed with sciatica and a herniated disc. His primary care physician and neurosurgeon believed his janitorial work significantly contributed to his condition. Neither physician had reviewed a description of his actual job duties or his complete medical records.
The college’s facilities supervisor testified that the pandemic reduced the janitor’s workload. Projects were halted, work was deliberately slowed to avoid layoffs, and the janitor worked fewer shifts. She disputed his descriptions of heavy lifting and intensive cleaning.
A repetitive-trauma injury is one which was: 1) caused by the performance of the claimant’s job; and 2) developed gradually over a period of time.
Did the janitor show his job duties led to a repetitive-trauma injury?
A. Yes. He performed physically demanding janitorial work, and two treating physicians linked his back condition to those duties.
B. No. The medical opinions because they relied on assumptions about the janitor’s duties.
If you selected B, you agreed with the court in Bowden v. Illinois Workers’ Compensation Commission, 2026 IL App (1st) 251986-U (10/09/26), which affirmed the Workers’ Compensation Commission’s denial of benefits.
The court explained that medical opinions can support causation, but the Commission may discount opinions based on incomplete or inaccurate factual assumptions. Here, the physicians based their causation opinions on generalized assumptions about janitorial work rather than verified descriptions of actual duties. Further, neither had reviewed his complete medical records. For those reasons, their opinions carried little weight.
Also, the supervisor’s testimony that during the pandemic work became less frequent and did not increase in difficulty undermined the janitor’s claims that repetitive activities caused his condition.
Because the janitor failed to establish causation, he lacked a compensable claim.
