Busted thumb--even a severe one--won't meet Kreiner threshold

Gary McManigal's lawsuit against George Levosinski was dismissed for failing to meet the Kreiner serious impairment threshold.  Levosinski was the at-fault in a collision that resulted in an "avulsion fracture of the ulnar base" of McManigal's right thumb.  McManigal was casted for only a few weeks, but was likely to have future restrictions on use of the hand, and to experience pain, arthritis and loss of range of motion.  The Court held that because these problems did not interfere with his jobs as a painter and as an apartment manager, and because the injury had little impact on his recreational life, McManigal could not sue for compensation.