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Case Law Database

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

Case No. No. 12627
Regular Panel Decision
May 06, 1954

American General Ins. Co. v. Bailey

This case concerns an appeal regarding a worker's compensation claim in Texas. Appellee Bailey sought compensation for permanent partial disability following a scaffold incident where he witnessed a co-worker's death and experienced severe fright and an anxiety state, despite sustaining only minor physical bruises. The appellant, American General Ins. Co., challenged the judgment, arguing that Bailey's neurosis, not directly resulting from a physical injury, was not compensable under the Workmen's Compensation Statutes. The Court of Civil Appeals of Texas, Galveston, reversed the trial court's decision, ruling that under Texas law, a neurosis or emotional condition is only compensable if it is a direct consequence of a physical injury, a condition not met in this case.

Workers' CompensationEmotional TraumaNeurosisPhysical InjuryAnxiety StateScaffold AccidentTexas LawMental HealthCompensable InjuryFright
References
2
Case No. MISSING
Regular Panel Decision

Johnson v. Schevenell Ready Mix, Inc.

Thomas Johnson appealed the dismissal of his worker's compensation claim for permanent disability benefits due to traumatic neurosis from an on-the-job accident in 1978. He sustained a scalping injury and other minor injuries when his "pay-loader" went over a cliff. While employer-selected physicians found no neurological disability, appellant's psychiatrist, Dr. Nancy H. Duckworth, diagnosed permanent disability from traumatic neurosis based on subjective complaints. The trial judge rejected Dr. Duckworth's testimony, citing an incorrect legal principle that medical evidence must have a basis other than subjective complaints. The Supreme Court clarified that T.C.A. § 24-718 allows medical opinions based on subjective findings from qualified experts to establish disability if found credible. The Court vacated the dismissal and remanded the case to the trial court for a new evaluation of witness testimony, including Dr. Duckworth's, and the introduction of further evidence regarding appellant's psychiatric treatment.

Disability BenefitsTraumatic NeurosisMedical EvidenceSubjective FindingsCredibility of WitnessRemandAppellate ReviewStatutory InterpretationPsychiatric EvaluationOn-the-job Injury
References
4
Case No. MISSING
Regular Panel Decision

Clayton v. Employers Mutual Liability Insurance Co. of Wisconsin

Regonald T. Clayton, the plaintiff-appellant, sought total and permanent disability benefits after an on-the-job eye injury led to its removal. He claimed general injuries including neurosis and central nervous system damage, arguing these were compensable under workmen’s compensation law. The defendant-appellee, Employers Mutual Liability Insurance Company of Wisconsin, contested these additional claims, asserting only the eye loss was compensable. The trial court ruled in favor of the defendant, limiting benefits to the specific eye injury. On appeal, the court reviewed evidence, including psychiatric testimony confirming a severe chronic anxiety reaction and injury to the central nervous system. The appellate court found sufficient probative evidence to support the plaintiff's general injury theories, emphasizing that neurosis causing physical disability is compensable in Texas. Consequently, the appellate court reversed the trial court's judgment and remanded the case for a new trial.

Workers' CompensationEye InjuryNeurosisCentral Nervous System InjuryTraumatic NeurosisTotal Permanent DisabilityAppellate ReviewReversed and RemandedMedical Expert TestimonyEvidentiary Issues
References
5
Case No. MISSING
Regular Panel Decision

Claim of Alves v. Hamilton

The claimant, a teacher, experienced multiple reassignments and received unfavorable evaluations, leading to claims of harassment and a causally related disability due to severe anxiety and mental anguish. Initially, an Administrative Law Judge ruled in the claimant's favor, but the Workers’ Compensation Board later rescinded the award. The Board determined there was no evidence of harassment and no causally related anxiety neurosis arising from employment. On appeal, the court reviewed the Board's decision, focusing on the substantial evidence and witness credibility. The court affirmed the Board’s decision, upholding its finding that the claimant was not harassed and that the factual determination was within the Board's sole province.

Workers' CompensationCausally Related DisabilityAnxiety NeurosisHarassmentSubstantial EvidenceCredibility of WitnessesFactual DeterminationAppellate ReviewTeaching EmploymentMental Anguish
References
2
Case No. MISSING
Regular Panel Decision
May 11, 1955

Bailey v. American General Insurance Company

The petitioner, Emery Eugene Bailey, a workman, suffered a disabling neurosis ('anxiety reaction' or 'anxiety state') after witnessing a co-worker's death and narrowly escaping himself. Although his physical injuries were minor, the psychic trauma rendered him unable to perform his work as an iron worker. The Court of Civil Appeals initially reversed a judgment in his favor, ruling his disability was not an 'injury' under the Workmen’s Compensation Statute. However, this court reversed that decision, holding that 'harm to the physical structure of the body' includes impairment of use or control of physical structures, even without direct organic damage, and remanded the case for further proceedings consistent with this opinion.

Workers' CompensationPsychic TraumaNeurosisAnxiety StatePhysical Injury InterpretationStatutory ConstructionCausationDisabilityEmotional DistressLegal Precedent
References
11
Case No. MISSING
Regular Panel Decision
Jun 02, 1997

Claim of Crawford v. New York City Health & Hospital Corp.

This case concerns an appeal from a Workers’ Compensation Board decision regarding a claimant who sustained a finger injury from a hypodermic needle in 1987. After an initial workers' compensation award, the case was reopened in 1993 when the claimant asserted a claim for a consequential posttraumatic neurosis or 'AIDS reaction phobia'. The employer argued that the two-year Statute of Limitations under Workers’ Compensation Law § 28 barred the psychiatric claim. However, the Board rejected this argument and affirmed the Workers’ Compensation Law Judge's decision to address the psychiatric condition. The Appellate Division affirmed the Board's decision, ruling that Section 28 does not bar amendment of a timely claim to include consequential injuries if a relationship exists between the subsequent claim and the initial injury.

Psychiatric Injury ClaimStatute of Limitations Workers' CompConsequential Psychological InjuriesHypodermic Needle InjuryAIDS Reaction PhobiaWorkers' Compensation Board AppealSection 28 BarAmendment of Timely ClaimCausally Related Disability
References
3
Case No. MISSING
Regular Panel Decision

Claim of Smith v. Steuben County Highway Department

This case concerns an appeal from a Workers’ Compensation Board decision that ruled a claimant sustained an accidental injury due to sexual discrimination and harassment at work, precipitating an anxiety neurosis disorder. The claimant, a flagger and the only woman on the job, testified to experiencing various forms of harassment from co-workers, including exposure, crude language, obscene gestures, property theft, and food tampering. Both her treating physician and a workers’ compensation physician opined that her psychological impairment was causally related to her employment. The employer contested the finding, arguing a lack of substantial evidence, but the court affirmed the Board’s decision, reiterating that psychological or nervous injury from psychic trauma is compensable, even with individual sensitivity or a pre-existing psychological illness.

sexual harassmentworkplace harassmentanxiety neurosispsychological injuryaccidental injurycausal relationshipworkers' compensationappealaffirmationpre-existing condition
References
6
Case No. MISSING
Regular Panel Decision

Smith v. Union Carbide Corp.

Russell B. Smith sued Union Carbide Corporation after his medical termination, seeking pension benefits or damages for wrongful discharge. Smith, employed for over 15 years, was terminated in 1961 due to a 'medical termination' after refusing recommended psychiatric treatment for his anxiety and traumatic neurosis. The dispute centered on whether he was permanently and totally disabled under the company's pension plan, and if the arbitration process, involving three physicians, was valid. The court found the arbitrators failed to consult as required by the collective bargaining agreement, making their decision non-binding. Ultimately, the court ruled that Smith was indeed permanently and totally disabled as of his termination date, granting him pension benefits and overruling the defendant's motion to re-refer the case to arbitration.

Pension DisputeWrongful TerminationDisability BenefitsCollective Bargaining AgreementMedical TerminationTraumatic NeurosisAnxiety ReactionFederal Court JurisdictionJudicial Review of ArbitrationContract Interpretation
References
4
Case No. MISSING
Regular Panel Decision

Goode v. New York City Transit Police Department

Petitioner, a transit police officer, sought an accident disability pension after suffering a nervous breakdown following administrative actions regarding his prior ordinary disability retirement application due to hearing loss. After being approved for retirement, his status was put under review for nine months, and he was eventually ordered back to work, triggering severe emotional distress. His subsequent application for accident disability, citing a mental-emotional injury from this process, was denied by NYCERS for lack of an 'accident' record. The court, analogizing to Workers’ Compensation concepts like 'compensation neurosis' and acknowledging that mental-emotional injuries can be compensable, denied NYCERS’ motion to dismiss. It granted the petitioner's application to the extent of compelling NYCERS to file an answer, allowing the case to proceed on its merits.

Accident Disability PensionCPLR Article 78Emotional TraumaNervous BreakdownWorkers' Compensation Law AnalogiesCompensation NeurosisMental-Emotional InjuryRetirement System ReviewTransit Police OfficerAdministrative Code § B3-40.0
References
8
Case No. MISSING
Regular Panel Decision

Henley v. Roadway Express

The case involves an employee who developed depressive neurosis attributed to working a third shift and resultant sleep difficulties. The trial court awarded 75% permanent partial disability benefits for a mental impairment caused by third shift work, considering it an injury arising out of employment. On appeal, the Supreme Court reversed the decision. The Court determined that the employee's mental disorder did not constitute an 'injury by accident' within the statutory limits, as general worry or emotional stress are insufficient for a compensation award. Furthermore, the court found that the inability to sleep at home was not a hazard incident to employment and lacked a causal connection to work conditions. Additionally, the court noted a fatal infirmity in the proof, as the clinical psychologist was not qualified to provide expert medical testimony on the permanency or extent of the disability.

Worker's Compensation LawDepressive NeurosisShift Work DisorderOccupational Mental HealthArising Out Of EmploymentIn The Course Of EmploymentPermanent Partial DisabilityMedical CausationPsychologist TestimonySupreme Court Appeal
References
10
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