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Missouri Supreme Court: work stress and workers’ compensation

On Behalf of | Oct 16, 2017 | Firm News, Workers' Compensation |

Here at Hall Ansley, P.C., in Springfield we fight for clients who have suffered work-related physical and mental injury or occupational disease in claims for workers’ compensation benefits. Emotional and psychological harm can present unique issues in a workers’ compensation claim, so it is smart to bring an experienced attorney on board as early as possible to advocate for the employee. 

Workers’ compensation for mental injury

Last month, the Missouri Supreme Court handed down a unanimous opinion that discusses the Missouri statute that controls workers’ compensation claims for “[m]ental injury resulting from work-related stress.” Specifically, the statute says that for this kind of injury to “arise out of and in the course of the employment” the claimant must prove that the “stress is work related and was extraordinary and unusual.”

Key to this case, the law also states that the “amount of work stress shall be measured by objective standards and actual events.”

Stress from working at car accident scenes 

Mantia v. Missouri Department of Transportation involves a DOT supervisor with more than 20 years of service. According to the opinion, she assisted with serious motor vehicle accident scenes on state highways up to four times each week, including some at which fatalities had occurred. Some of the human suffering she observed was graphic and disturbing. 

In 2008, the claimant applied for workers’ compensation based on mental injury after a diagnosis of depression. An administrative law judge or ALJ denied her claim after a hearing where both sides presented medical experts. The ALJ said that she had not shown that the stress at work was extraordinary and unusual, to use the language of the law. 

The Labor and Industrial Relations Commission reversed the ALJ and awarded benefits for “50 percent permanent partial disability of the body as a whole and the right to future medical care for her work-related mental injury.” On appeal, the Supreme Court sent back the case for Commission review after interpreting the “plain and ordinary meaning” of the statute. 

Objective stress 

The court found that the commission had not correctly applied an “objective” standard to the question whether the stress was extraordinary and unusual. 

The court elaborated that the question was not whether this supervisor experienced “extraordinary and unusual stress,” but whether “the same or similar actual work events would cause a reasonable highway worker extraordinary and unusual stress.”

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