Claim of Cook v. East Greenbush Police Department
The claimant, a patrol officer for the East Greenbush Police Department, filed for workers' compensation benefits after being diagnosed with posttraumatic stress disorder following a traumatic incident in January 2009 involving an armed suspect. His claim was denied by a Workers’ Compensation Law Judge and subsequently affirmed by the Workers’ Compensation Board, who found that the events giving rise to his injury were part of his job responsibilities. The Appellate Division affirmed the Board's decision, reiterating that for a mental injury from work-related stress to be compensable, the stress must exceed that normally encountered in the work environment. The court concluded that while the specific encounter was "extraordinary," the possibility of needing deadly force is an inherent part of a police officer's regular duties, regardless of department size. Therefore, the Board's decision to deny benefits was upheld.