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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

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. ADJ8222509
Regular
May 12, 2015

SARAI CRUZ CANSECO vs. NEW DESSERTS, INC., WAUSAU UNDERWRITERS INSURANCE COMPANY

This case concerns whether an employee's psychiatric injury claim is barred by Labor Code section 3208.3(d), which typically requires six months of employment, unless the injury resulted from a "sudden and extraordinary employment condition." The applicant, employed for less than six months, injured her wrist and ankle when a bakery cart collapsed. The majority affirmed the WCJ's decision, finding the cart's collapse constituted a sudden and extraordinary event that did not bar the psychiatric claim. The dissenting commissioner argued the collapse was an unforeseen accident but not extraordinary enough to bypass the six-month rule, differentiating it from truly sudden and extraordinary events.

Labor Code section 3208.3(d)psychiatric injurysudden and extraordinary employment conditionsix-month employment rulebakery cart collapseindustrial injurycompensable consequenceroutine employment eventoccupational hazardno-fault system
References
3
Case No. MISSING
Regular Panel Decision

Texas Employers Insurance Ass'n v. Duree

This case addresses the interpretation of "sudden and immediate" for hernia compensability under the Texas Worker's Compensation Act. Morris Arden Duree, an employee, experienced a groin injury at work and discovered a hernia lump ten days later, subsequently filing for benefits. The defendant, Texas Employers Insurance Association (TEIA), challenged the jury's finding, arguing the ten-day delay negated the "sudden and immediate" requirement and that the jury instructions were improper. The appellate court affirmed the trial court's judgment, ruling that "sudden and immediate" is a relative term and that a ten-day interval does not automatically preclude compensation when a causal link is evident. Furthermore, the court found the jury instructions to be legally sound and not an improper comment on the evidence.

HerniaWorker's Compensation ActStatutory InterpretationJury InstructionsMedical EvidenceCausationAppellate LawTexas Court of AppealsInjury ClaimEmployer Liability
References
26
Case No. ADJ2210692 (SDO 0348182), ADJ4664046 (SDO 0348183)
Regular
Nov 27, 2012

MILTON GUZMAN vs. SELECT ELECTRIC, ZURICH NORTH AMERICA

This case involves a worker's compensation claim for a psychological injury. The defendant argued the applicant did not meet the six-month employment requirement under Labor Code 3208.3 or the "sudden and extraordinary" exception. The Board affirmed the finding of industrial injury to the psyche, determining the applicant's intermittent employment, including time after the injury, constituted sufficient "actual service." A dissenting opinion argued the applicant's service was less than six months and the backhoe injury was not "sudden and extraordinary."

Labor Code 3208.3Petition for ReconsiderationFindings and Awardindustrial injurypsychestrokestreet light technicianSelect ElectricZurich North Americaactual service
References
10
Case No. ADJ850378 (OAK 0327145)
Regular
Jul 20, 2009

JUAN C. CAMPOS vs. EXPERT TREE SERVICE, STATE COMPENSATION INSURANCE FUND

This case involves an applicant injured while working as a tree climber, who sustained multiple physical injuries and sought compensation for a psychological injury. The defendant contested the psychological injury claim, arguing it didn't meet the "sudden and extraordinary employment condition" exception to the six-month employment rule for such claims. The Board granted reconsideration, reversing the finding of a compensable psychological injury because the event, while sudden, was not extraordinary for the nature of the employment. The case is remanded for a new rating of orthopedic permanent disability.

Labor Code section 3208.3sudden and extraordinary employment conditionpsychiatric injurypermanent disabilityAMA Guidessequelaecompensable consequenceindustrial injuryreconsiderationfindings award and order
References
5
Case No. ADJ1332729 (RDG 0121425)
Regular
Feb 18, 2011

LINEA HIMES vs. STATE OF CALIFORNIA, DEPARTMENT OF SOCIAL SERVICES-IHSS, Legally Uninsured, STATE COMPENSATION INSURANCE FUND/STATE CONTRACT SERVICES, Adjusting Agency

The Workers' Compensation Appeals Board granted reconsideration to address the compensability of the applicant's psychiatric injury. The defendant argued the applicant's psychiatric injury was not compensable due to less than six months of employment, as required by Labor Code section 3208.3(d). While the WCJ found the auto accident was a "sudden and extraordinary event" exempting the six-month rule, the Board remanded the case. The Board requires the WCJ to first determine the applicant's exact length of employment before addressing the "sudden and extraordinary" exception.

Workers' Compensation Appeals BoardLegally UninsuredAdjusting AgencyFindings and AwardIndustrial InjuryBack InjuryPsyche InjuryPermanent DisabilityFurther Medical TreatmentTraumatic Automobile Accident
References
4
Case No. ADJ6754663
Regular
Jun 21, 2010

RUBEN CASTILLO vs. J. JOHNSON & COMPANY, INC., STATE COMPENSATION INSURANCE FUND

This case concerns an applicant injured within six months of employment, raising a claim for psychiatric injury. Labor Code Section 3208.3(d) generally bars such claims unless the injury results from a "sudden and extraordinary" employment condition. The Appeals Board, in a majority decision, found the applicant's injury from a backhoe bucket was not extraordinary, thus reversing the WCJ's finding and barring the psychiatric claim. A dissenting opinion argued that being struck by a backhoe bucket is not a regular or routine incident and should qualify as a sudden and extraordinary event.

Labor Code Section 3208.3(d)sudden and extraordinary employment conditionpsychiatric injurysix-month employment rulereconsiderationFindings and OrderWCJReport and Recommendationbackhoe bucketworkplace violence
References
4
Case No. ADJ3926578 (GOL 0088323)
Regular
Apr 15, 2010

Joseph Villa vs. FOOD 4 LESS, ESIS/ACE USA

The Appeals Board granted reconsideration of a prior award finding applicant sustained a 100% permanent disability due to back and psyche injuries. Defendant argued against the psychiatric injury claim based on the applicant's short employment duration and lack of a sudden/extraordinary event. The Board found the medical evidence regarding the psychiatric injury's causation was insufficient and potentially contradictory. Therefore, the case is returned to the trial level for further development of the record on causation and to address the six-month employment rule and the "sudden and extraordinary" event requirement if applicable.

Workers' Compensation Appeals BoardPsychiatric InjurySudden and Extraordinary Employment ConditionPredominant CauseSubstantial Medical EvidenceRes JudicataLachesApportionmentSomatizationDerivative Injury
References
21
Case No. ADJ10248888
Regular
Jan 23, 2019

JUAN PAQUINI vs. SPRING HILL JERSEY CHEESE, INC., dba PETALUMA CREAMERY

Applicant sought reconsideration of a WCJ's finding that his vehicle accident was not a "sudden and extraordinary" employment condition, which would have allowed compensation for psychiatric injury despite less than six months of employment. The Appeals Board affirmed the WCJ's decision, finding the applicant's testimony regarding the alleged steering wheel lock was contradictory and lacked credibility. Furthermore, the Board determined the applicant failed to prove the incident was uncommon or unexpected beyond personal experience. Consequently, the original order was amended to explicitly state the injury did *not* fall under the sudden and extraordinary exception.

AOE/COELabor Code section 3208.3(d)sudden and extraordinarypsychiatric injuryless than six months employmentmotor vehicle accidentsteering wheel lockedcredibility determinationpreponderance of the evidencefactual inquiry
References
12
Case No. ADJ6561833
Regular
Aug 19, 2011

Stephen Resetar vs. CONSTRUCTORA AMORA, STATE COMPENSATION INSURANCE FUND

This case involves a worker, Stephen Resetar, who sustained a physical injury to his spine after falling from a ladder. Resetar also claimed a psychological injury, but had been employed for less than six months. Labor Code § 3208.3(d) generally bars compensation for psychiatric injuries in such cases unless caused by a "sudden and extraordinary employment condition." The Appeals Board found that Resetar's fall, caused by dizziness and falling from a ladder, did not qualify as a sudden and extraordinary event. Therefore, Resetar's claim for psychiatric injury is barred, and reconsideration is granted to reflect this decision.

Labor Code § 3208.3(d)psyche injurysudden and extraordinary employment conditionsix-month employment rulereconsiderrescindcompensable injuryfall from ladderdizzinessdehydration
References
4
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