RUSSELL MCFADDEN (deceased); RENEE MCFADDEN, JAZMINE MCFADDEN, and RUSSELL MCFADDEN, II vs. KEOLIS TRANSIT AMERICA; LIBERTY MUTUAL INSURANCE COMPANY
The Workers' Compensation Appeals Board affirmed a judge's decision denying a death benefit claim for Russell McFadden, who died by suicide. The applicant contended his death resulted from an industrial psychiatric injury due to occupational stress. Medical evidence indicated that industrial factors were only a 35% cause of the decedent's psychiatric disorder, with significant pre-existing conditions and drug use being the predominant causes. Furthermore, the Board found no evidence that the suicide was an irresistible impulse, distinguishing it from cases where an industrial injury directly causes a mental condition that prevents resistance to suicide. Therefore, the claim was denied based on the psychiatric injury not being predominantly industrially caused and the suicide not meeting the criteria for compensability.