CompFox Logo
AboutWorkflowFeaturesPricingCase LawInsights

Updated Daily

Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Claim of Altes v. Petrocelli Electric Co.

The case involves an appeal from a Workers' Compensation Board decision denying death benefits to a claimant whose decedent committed suicide after a work-related injury. The Board concluded there was no causal relationship and that severe depression was insufficient for a suicide claim. The appellate court found the Board applied an incorrect legal standard, stating that depressive reactions can qualify as 'brain derangement' and a work-related injury only needs to be a 'contributing cause' to the ensuing suicide. The court reversed the Board's decision and remitted the matter for further proceedings consistent with the correct legal standard.

Suicide ClaimDeath BenefitsCausationDepressionMental InjuryWork-Related InjuryLegal Standard ErrorAppellate CourtRemittal
References
3
Case No. 84-192
Regular Panel Decision

Gagne v. City of Galveston

James Gagne was arrested for public intoxication and subsequently died by suicide in the Galveston City Jail. His family, the plaintiffs, filed a civil rights complaint under 42 U.S.C. § 1983 against the City of Galveston and its Police Department, alleging deliberate indifference and negligence in preventing the suicide. Specific allegations included failure to remove Gagne's belt, inadequate screening for suicidal tendencies, and insufficient training and policies. The District Court granted the defendants' motion for summary judgment, concluding that the plaintiffs failed to demonstrate a constitutional deprivation or that the injury resulted from an official municipal policy or custom. The federal civil rights claims were dismissed with prejudice, and pendent state claims were dismissed without prejudice due to the lack of federal jurisdiction.

SuicideCivil RightsSection 1983Municipal LiabilitySummary JudgmentDeliberate IndifferencePretrial DetaineePolice MisconductNegligenceConstitutional Deprivation
References
39
Case No. ADJ9216410
Regular
Dec 28, 2020

RAMON CHACON ALCALA vs. SACRAMENTO COUNTY JAIL

This case involves a Sacramento County Jail inmate, Ramon Chacon Alcala, who claims an industrial injury to his back and groin from lifting dough in the jail bakery. Although the applicant's credibility as a historian was questioned, the Workers' Compensation Appeals Board denied the defendant's Petition for Reconsideration. The Board adopted the findings of the administrative law judge who concluded that medical evidence from examining physicians provided substantial support for an industrial injury. Despite applicant's credibility issues, the physicians' opinions on causation based on reasonable medical probability were deemed sufficient to uphold the award.

WCABPetition for ReconsiderationFindings and AwardIndustrial InjurySacramento County JailInmateBakeryHerniaBack InjuryQualified Medical Examiner
References
0
Case No. ADJ6748204
Regular
Jan 17, 2012

Stewart Espinoza vs. Los Angeles County Jail, Tristar Irvine

The Workers' Compensation Appeals Board granted reconsideration and reversed a judge's finding of employment for inmate Stewart Espinoza. The Board found that Espinoza, an inmate injured while working in the County Jail kitchen, was not an employee for workers' compensation purposes. This was because a County ordinance allowed inmates to be compelled to perform labor, negating a voluntary employment relationship. Therefore, the applicant was not an employee entitled to workers' compensation benefits.

Workers' Compensation Appeals BoardLos Angeles County Jailinmate laboremployee statusvoluntary workcompulsory laborPenal Code Section 4017Government Code Section 25359SCIF v. Workmen's Comp. Appeals Bd. (Childs)Parsons v. Workers' Comp. Appeals Bd.
References
3
Case No. MISSING
Regular Panel Decision

Johnson v. Nassau University Medical Center

This action concerns medical malpractice and wrongful death following a patient's suicide. The plaintiff, as the decedent's executor, appealed an order granting summary judgment to defendants Kathryn Zajac, a social worker, and Catholic Charities, her employer. The decedent, suffering from depression, expressed suicidal ideation to Zajac, who then consulted psychiatrist Kamil Jaghab. Jaghab determined a high suicide risk and advised hospital referral. The decedent was transported to Nassau University Medical Center and examined by psychiatrist Mukesh Prakash Sharoha, who, unaware of the specific suicide plan due to lack of communication from the Clinic, discharged him. The decedent committed suicide the next day. The appellate court found triable issues of fact regarding Zajac's duty to communicate with the hospital and follow up, reversing the lower court's grant of summary judgment.

medical malpracticewrongful deathsuicide preventiondepression treatmentsocial worker negligencepsychiatric assessmentvicarious liabilitysummary judgment motionprofessional standard of careproximate causation
References
3
Case No. E2000-02551-SC-R11-CV
Regular Panel Decision
May 06, 2003

Shirley Shelburne v. Frontier Health

Plaintiff Shirley A. Shelburne, individually and as next friend of her minor son, brought suit against Frontier Health and Woodridge Hospital for the wrongful death of her husband, Richard Lee Shelburne, who committed suicide in jail. This occurred after a psychiatric evaluation by Richard Kirk, an employee of Frontier Health. The trial court and Court of Appeals granted summary judgment to the defendants, ruling they were immune from vicarious liability because Kirk was deemed a state employee. The Supreme Court granted review to determine if summary judgment was properly granted in light of the Johnson v. LeBonheur Children’s Medical Center decision. The Court held that Johnson governs the present case, finding Frontier and Woodridge are not immune from liability for the acts or omissions of their immune employee. Consequently, summary judgment was not appropriate, and the case was reversed and remanded for further proceedings.

Wrongful DeathRespondeat SuperiorGovernmental ImmunityState Employee ImmunityPsychiatric EvaluationMental Health ServicesSuicideVicarious LiabilityAgency RelationshipSummary Judgment
References
6
Case No. MISSING
Regular Panel Decision

JCW Electronics, Inc. v. Garza

This appeal concerns a personal injury lawsuit filed against JCW Electronics, Inc. after an inmate's suicide in a Port Isabel City Jail cell using a JCW-installed telephone. Initially, the trial court rendered judgment based on breach of contract and fraud, overriding a jury verdict that also included findings of negligence and breach of implied warranty. The appellate court reversed the breach of contract and fraud judgments, citing pleading deficiencies and the Texas Proportionate Responsibility Statute, which barred fraud recovery due to the deceased's comparative responsibility. However, the court affirmed the judgment based on breach of implied warranty of fitness, finding sufficient evidence that the telephone was unsafe for unsupervised inmate use and proximately caused the death. The final decision modified the trial court's judgment by reversing attorney's fees and adjusting court costs, ultimately affirming recovery for the appellees under the breach of implied warranty claim.

Product LiabilityImplied WarrantyWrongful DeathPersonal InjuryJail SuicideTelephone Equipment SafetyAppellate ProcedureContract LawTort LawProportionate Responsibility
References
56
Case No. ADJ10275361
Regular
Jan 27, 2020

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.

Workers Compensation Appeals BoardRenee McFaddenKeolis Transit AmericaLiberty Mutual Insurance CompanyADJ10275361Opinion and Decision After ReconsiderationIndustrial Psychiatric InjuryOccupational Stress and StrainCompensable Death ClaimLabor Code Section 3600(a)(6)
References
6
Case No. MISSING
Regular Panel Decision
Mar 28, 2014

Gallen v. County of Rockland

This case concerns an appeal by defendants Jay L. Lombard and Brain Behavior Center-Rockland from the denial of their motion for summary judgment in a medical malpractice and wrongful death action. The plaintiff's decedent, after a suicide attempt, was discharged from Valley Hospital with a safety contract. The same day, he was seen by defendant Lombard, a neurologist, who performed a suicide assessment, prescribed medication, and concluded there was no immediate risk, but the decedent committed suicide a week later. The Supreme Court denied the defendants' motion for summary judgment, and the appellate court affirmed, finding a triable issue of fact regarding whether Lombard departed from good medical practice by failing to obtain prior records and conducting an inadequate suicide assessment.

Medical MalpracticeWrongful DeathSuicide AssessmentNeurologist LiabilitySummary JudgmentAppellate ReviewStandard of CareProximate CausePatient DischargePsychiatric Treatment
References
6
Case No. MISSING
Regular Panel Decision
Nov 05, 2002

Claim of Potter v. Curtis Lumber Co.

The claimant's decedent, a former marketing design manager for Curtis Lumber, committed suicide after experiencing work-related stress. The Workers’ Compensation Board awarded the claimant death benefits, finding the suicide was precipitated by a depressive illness causally linked to severe workplace stress. Curtis Lumber and its workers' compensation carrier appealed, arguing the stress was not greater than that usually found in a normal work environment and that lawful personnel decisions caused the suicide. The Appellate Division affirmed the Board's decision, concluding that the testimony of a board-certified psychiatrist provided substantial evidence that the decedent's suicide was causally related to abnormal work-related stress and implicitly rejecting the carrier's defense under Workers’ Compensation Law § 2 (7).

SuicideWork-Related StressDepressive IllnessWorkers' Compensation Death BenefitsCausal RelationshipSubstantial EvidenceMedical Expert TestimonyPersonnel DecisionsAppellate ReviewAffirmed Decision
References
11
Showing 1-10 of 183 results

Ready to streamline your practice?

Apply these legal strategies instantly. CompFox helps you find decisions, analyze reports, and draft pleadings in minutes.

CompFox Logo

The AI standard for workers' compensation professionals. Faster research, deeper analysis, better outcomes.

Product

  • Platform
  • Workflow
  • Features
  • Pricing

Solutions

  • Defense Firms
  • Applicants' Attorneys
  • Insurance carriers
  • Medical Providers

Company

  • About
  • Insights
  • Case Law

Legal

  • Privacy
  • Terms
  • Trust
  • Cookies
  • Subscription

© 2026 CompFox Inc. All rights reserved.

Systems Operational