In a June 4, 2013 decision, the Supreme Court of Ohio held that an employee can only seek workers’ compensation benefits for a mental-health issue if that mental-health issue is the direct result of a physical injury.
The ruling came down in the case of Armstrong v. John R. Jurgensen Co. in which an employee filed a workers’ compensation claim for both physical injuries and post-traumatic stress suffered as a result of being involved in a trucking accident while working. The Ohio Bureau of Workers’ Compensation approved the employee’s claim for the physical injuries but not for the post-traumatic stress. The employee then sued for additional benefits to compensate the post-traumatic stress suffered. The Supreme Court sided with the Bureau after determining that, under Ohio law, workers’ compensation benefits must be connected to some physical injury. Based on this conclusion, the Court deferred to the finding in the lower court that the employee’s post-traumatic stress was not the direct result of any physical injuries and was thus not compensable under workers’ compensation law.
Ultimately, the Court drew the distinction here that an employee could receive workers’ compensation benefits for a mental-health issue that was caused by a physical injury suffered on the job but not for a mental-health issue caused by merely witnessing a traumatic event on the job. In this decision, the Court’s ruling turned on the expert testimony explaining the cause of the employee’s post-traumatic stress.