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Case Law Database

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

Case No. MISSING
Regular Panel Decision
Oct 14, 2003

Claim of Berkley v. Irving Trust Co.

In 1984, the claimant, employed at Irving Trust Company, experienced a job-stress-induced psychotic episode, for which workers' compensation benefits were initially established. By 1995, a Workers’ Compensation Law Judge (WCLJ) and the Workers' Compensation Board determined that her disability was no longer causally related. The case was reopened in 2000 after another psychotic episode, which the claimant alleged was causally linked to her prior employment stress. However, in 2003, a WCLJ and the Board found the latest episode was not causally related to her employment and applied Workers’ Compensation Law § 25-a. The Appellate Division affirmed the Board's decision, giving deference to its resolution of conflicting medical expert testimony, which attributed the recent episode to stress from graduate school rather than a remanifestation of the prior work-related breakdown.

psychotic episodecausally related disabilityworkers' compensation benefitsmedical expert testimonycredibility assessmentpersonality disorderstress-induced illnessappellate reviewWorkers’ Compensation Law § 25-aprior employment stress
References
3
Case No. MISSING
Regular Panel Decision

In re Eastern District Repetitive Stress Injury Litigation

The defendants sought to transfer 78 repetitive stress injury (RSI) cases from the Eastern District of New York to districts where the claims arose, also seeking severance of individual claims. Over 450 RSI cases, involving over 1,000 plaintiffs against more than 100 equipment manufacturers, were initially consolidated in the Eastern District. However, the Second Circuit later vacated the consolidation orders, finding it an abuse of discretion due to lack of common facts and varying state laws. Relying on this guidance, the court granted transfer in 75 cases and denied it in three, citing factors such as convenience of parties and witnesses, judicial economy, and the public interest in local adjudication of local controversies. The court also ordered severance where necessary to facilitate transfer.

Transfer of VenueMultidistrict LitigationRepetitive Stress InjuryProducts LiabilityForum Non ConveniensSeverance of ClaimsConsolidation of CasesJudicial EconomyWitness ConvenienceChoice of Forum
References
16
Case No. 03-21-00120-CV
Regular Panel Decision
Feb 24, 2022

Brian Manley, Chief of Austin Police Department Brian Manley, Individually Commander Mark Spangler, Austin Police Department Lt. Jerry Bauzon, Austin Police Department Officer Benjamin Bloodworth, Austin Police Department Officer Collin Fallon, Austin Police Department Sgt. Eric Kilcollins, Training Coordinator, Austin Police Academy And Officer Shand, Lead Instructor, Stress Reaction Training, Austin Police Academy v. Christopher Wise

Christopher Wise, a former Austin Police Academy cadet, sued Brian Manley (APD Chief) and six other APD officers after sustaining severe injuries, including heat exhaustion and stroke, during a stress reaction training in October 2018. Wise alleged that officers intentionally discouraged cadets from hydrating despite high temperatures and failed to provide timely medical aid. The defendants sought dismissal under the Texas Tort Claims Act's election-of-remedies provisions. The district court dismissed claims against the City of Austin and APD but not against the individual officers. The appellate court reversed the district court's decision, ruling that Wise's claims against the individual officers were based on conduct within the scope of their employment and could have been brought under the TTCA, thus mandating their dismissal.

Texas Tort Claims ActGovernmental ImmunityElection of RemediesScope of EmploymentPolice MisconductCadet InjuryHeat IllnessSupervisor NegligenceAppellate CourtReversal
References
25
Case No. MISSING
Regular Panel Decision

Guillo v. NYC Housing Authority

Claimant appealed a Workers’ Compensation Board decision from February 6, 2013, which denied her claim for benefits related to work-induced depression, anxiety, and posttraumatic stress disorder. The Board had reversed a Workers’ Compensation Law Judge's finding, concluding that the claimant failed to demonstrate that the work-related stress was 'greater than that which other similarly situated workers experienced.' The appellate court affirmed the Board's determination, finding substantial evidence supported that the stress was not unusual. The court also noted that claimant's argument regarding a stress-related physical injury was unpreserved for review due to not being raised before the Board.

work-related depressionoccupational stressmental injury claimunusual stress standardworkers' compensation benefits denialappellate affirmanceemployer's testimony creditedclaimant's credibilityunpreserved argument
References
6
Case No. MISSING
Regular Panel Decision

Claim of Pinto v. Southport Correctional Facility

Claimant, a teacher at a maximum-security correctional facility, experienced severe head pains and disorientation, leading to a claim for workers' compensation benefits for work-related stress, depression, headaches, and memory loss. The Workers’ Compensation Board disallowed the claim, finding the presumption of work-related injury rebutted and concluding that the stress experienced was not greater than that usually encountered in his work environment. On appeal, the court affirmed the Board’s decision to deny the claim on the merits. While the court disagreed with the Board's finding that the claim was barred by Workers’ Compensation Law § 2 (7) due to personnel decisions, it upheld the Board's alternate basis for denial, stating that the claimant failed to show the stress was beyond what similarly situated workers experienced.

Workers' CompensationStress-related injuryMental injuryCausationPresumption of injuryRebuttal of presumptionPersonnel decisionWork environmentCorrectional facilityTeacher
References
14
Case No. MISSING
Regular Panel Decision
Feb 06, 2004

Claim of Mason v. Reunion Industries, Inc.

The case involves an appeal from a Workers’ Compensation Board decision denying benefits to a claimant for work-induced stress exacerbating a preexisting panic disorder and depression. The Board had ruled that the stress was typical to the work environment and not causally related, also citing Workers’ Compensation Law § 2 (7). The appellate court disagreed with the Board's interpretation of § 2 (7) as a bar. However, the court affirmed the denial of benefits, finding substantial evidence supported the Board's conclusions that the stress was not unusual for the work environment and that there was no causal connection between the work stressors and the claimant's condition, crediting the employer's expert medical opinion.

Workers' CompensationMental HealthStressPanic DisorderDepressionCausationExpert TestimonySubstantial EvidenceAppellate ReviewMedical Opinion
References
8
Case No. 2025 NY Slip Op 06529
Regular Panel Decision
Nov 24, 2025

Matter of McLaurin v. New York City Tr. Auth.

The Court of Appeals addressed consolidated appeals concerning four claimants seeking Workers' Compensation benefits for psychological injuries (e.g., PTSD) due to COVID-19 workplace exposure in 2020. The Workers' Compensation Board had disallowed these claims, finding the stress was not greater than that experienced by similarly situated workers. The Appellate Division reversed, arguing the Board failed to consider "particular vulnerabilities" and applied "disparate burdens." The Court of Appeals reversed the Appellate Division, reinstating the Board's decisions. It held that particular vulnerabilities are immaterial and that emotional stress-induced psychological injury is compensable only if the stress is "greater than that which other similarly situated workers experienced in the normal work environment," a standard the claimants did not meet. The court also noted recent legislative amendments to the Workers' Compensation Law that establish a more favorable standard for PTSD claims, but clarified they do not apply retroactively to these cases.

Workers' CompensationPsychological InjuryPTSDCOVID-19 ExposureWorkplace StressCompensability of ClaimsAccidental InjuryAppellate Division ReversedCourt of Appeals DecisionSimilarly Situated Workers Standard
References
18
Case No. MISSING
Regular Panel Decision

Goodloe v. State

Veronica Goodloe, an employee, appealed a judgment from the Tennessee Claims Commission denying her workers' compensation claim against Columbia State Community College. Goodloe suffered a mental breakdown and overdose after her supervisor informed her she might be terminated, exacerbating her pre-existing depression. The Claims Commission initially granted summary judgment to the employer, finding the mental injury was not caused by a sudden, stressful work-related event. The Special Workers’ Compensation Appeals Panel reversed and remanded, but the employer sought a full Court review. The Supreme Court of Tennessee ultimately affirmed the Claims Commission's judgment, ruling that Goodloe's mental injury was not compensable under workers' compensation law as it did not result from an identifiable stressful, work-related event producing sudden fright, shock, or excessive unexpected anxiety. The court reiterated that general work-related stress, or a normal adverse employment action, does not qualify for compensation.

Mental InjuryPsychiatric ConditionDepressionStress-related IllnessCompensabilitySudden Mental StimulusWork-related EventEmployment TerminationSummary JudgmentAppellate Review
References
15
Case No. 2024-80-0970
Regular Panel Decision
Nov 06, 2024

Coleman, Dwaine v. W. K.Kellogg

Dwaine Coleman sought workers' compensation benefits for a mental injury, claiming a panic attack, anxiety, and high blood pressure after hitting a machine at work with a hammer. The employer, W.K. Kellogg, argued that the incident stemmed from ordinary job stress, making it non-compensable. Applying an objective two-part test for mental injuries, the Court found that the incident, involving regular machine breakdowns and repairs, was not extraordinary compared to the stress typically experienced in such a role. Consequently, Mr. Coleman failed to demonstrate a likelihood of prevailing on the merits, leading to the denial of his request for medical and temporary benefits.

Workers' Compensation ClaimsMental Injury ClaimPanic AttackAnxiety DisorderWork-Related StressObjective TestCompensabilityExpedited HearingBenefits DeniedRotator Cuff Surgery
References
4
Case No. MISSING
Regular Panel Decision
Jan 17, 1996

Claim of Palevsky v. New York City Board of Education

In 1986, while working as an education associate in the Bronx, the claimant sustained a fractured nose due to a student altercation and filed a timely workers' compensation claim, receiving benefits. The case remained open for a pending nasal surgery issue. Years later, in 1992, the claimant sought compensation for alleged consequential posttraumatic stress disorder. The self-insured employer, the New York City Board of Education, argued that Workers' Compensation Law § 28, a two-year statute of limitations, barred this new claim. However, both the Workers' Compensation Law Judge and the Board affirmed that Section 28 does not apply to consequential injuries. Upon appeal, the Court concurred, holding that a subsequent claim for disability compensation related to injuries in an earlier, timely claim is not barred by the two-year limit for amendment.

Workers' CompensationPosttraumatic Stress DisorderStatute of LimitationsConsequential InjuryWorkers' Compensation Law § 28Time BarBoard DecisionAppealWorkplace InjuryNasal Fracture
References
3
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