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Christina Lumbreras

Christina Lumbreras is a Legal Editor for Workers' Compensation Report, a publication of our parent company, LRP Publications. She can be reached at riskletters@lrp.com

You Be the Judge

Is Parking Lot Stumble Compensable?

The court must consider whether an employer's ability to designate where a worker parks her car plays a role in the compensability of a parking lot injury.
By: | August 28, 2014 • 2 min read
You Be the Judge

An assistant manager for a retail clothing store parked in the back lot of the shopping center near the back door of the store. When she left work, she walked to her car and put her purse on the passenger seat, and while walking around the back of the car to the driver’s side, she slipped and fell on black ice. She injured her right shoulder.

The assistant manager sought workers’ compensation benefits. The store denied the claim, arguing that the injury was not compensable because it did not occur on the store’s operating premises.

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The assistant manager said that when she was hired, the store manager and a manager of the shopping center told her to park in the back lot. She admitted that other store employees parked in the front lot. Other employees said that other than during the holiday season, they received no instructions on where to park. No signs designated the back lot as an employee parking lot.

The administrative law judge found that the assistant manager’s injury did not occur within the store’s operating premises and was not compensable. The Workers’ Compensation Board reversed, finding that even though the store had no control over the parking lot, it controlled where employees parked. The board found that the assistant manager’s injury was within the store’s operating premises.

The store appealed.

Poll Question

Was the board correct in granting benefits to the assistant manager?

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The court explained that in determining whether a parking facility is within an employer’s parking premises, it considers: 1) whether the employer directly or indirectly owns, maintains, or controls the parking facility; 2) whether the employer designated where in the parking facility its employees are to park; 3) whether the employee parked in the designated area; and 4) whether the employee was taking a reasonable path from her car to her workstation when injured.

The parties agreed that the store did not own the parking facilities and had no obligation to maintain the facilities. No evidence showed that any parking spaces were specially allocated to the store. Also, no evidence showed that the store had any influence over the shopping center’s maintenance of the parking facilities. The court found that the store exercised no control over the parking facilities.

B is incorrect. Although the assistant manager said she had been told to park in the back lot, other employees said they received no such instructions. The court concluded that the store did not tell employees where to park.

C is incorrect. A dissenting judge opined that the store had indirect control over the parking lot. However, the majority concluded that the store had no control over the parking lot.

How the court ruled: A. The Kentucky Supreme Court held that the assistant manager was not entitled to benefits for her injuries. Hanik v. Christopher & Banks, No. 2012-SC-000791-WC (Ky. 06/19/14).

Editor’s note: This feature is not intended as instructional material or to replace legal advice.

Christina Lumbreras is a Legal Editor for Workers' Compensation Report, a publication of our parent company, LRP Publications. She can be reached at riskletters@lrp.com
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View From the Bench

Workers’ Comp Docket

Significant workers' comp legal decisions from around the country.
By: | August 28, 2014 • 11 min read
Docket

Employee’s Perception of Being Trapped Doesn’t Justify PTSD Benefits

Rizzo v. Kean University, No. A-0174-13T4 (N.J. Super. Ct. App. Div. 06/11/14, unpublished)

Ruling: In an unpublished decision, the New Jersey Superior Court, Appellate Division held that a professor’s psychiatric disability was not compensable.

What it means: In New Jersey, for a mental condition to be compensable, the objectively stressful working conditions must be peculiar to the particular workplace.

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Summary: An assistant professor for Keane University claimed that the director of the undergraduate program entered her office, closed the door, and confronted her about her tone of voice in a conversation they had earlier that day. The professor claimed that the director kept her hand on the door and would not let her leave. The professor perceived the director’s actions as a threat of physical violence. The director said that she did not prevent the professor from leaving the office and she was of a smaller stature than the professor, so she could not have threatened to overpower her. After the incident, the professor saw a psychologist who diagnosed her with post-traumatic stress disorder. The professor sought benefits. The New Jersey Superior Court, Appellate Division held that she was not entitled to benefits.

The psychologist believed that the professor felt trapped when the office door was closed, bringing back memories of childhood abuse. The psychologist noted that the director’s position of authority, not her size, recreated the trapped feeling and triggered the PTSD.

The court rejected the professor’s argument that she demonstrated a causal relationship between her diagnosis and the incident. The court found that the incident was not objectively stressful based on the director’s testimony that she was not blocking the door or threatening the professor. Also, the size disparity between the professor and director could not render the incident objectively stressful. The court found the incident involved a brief meeting in an office with the door closed, a normal event in a work environment.

The court concluded that even though the incident may have “triggered” the professor’s PTSD, it did not cause the disability.

Nurse Can’t Prove Flu Shot Caused Bursitis

Simmons v. Nemours, No. N13A-10-008 CLS (Del. Super. Ct. 06/04/14)

Ruling: The Delaware Superior Court held that a nurse was not entitled to benefits for her bursitis.

What it means: In Delaware, a worker cannot establish causation when a doctor opines that the worker’s condition was from a separate nonwork-related injury.

Summary: A registered nurse for Nemours received an influenza vaccination as part of her employment. When the injection was administered, she felt an intense pain. A few days later, she repacked 10 boxes in her garage. The next morning, the nurse experienced soreness in her muscles. Later, she visited her doctor complaining of a sore left arm. An MRI showed bursitis. The nurse sought workers’ compensation benefits. The Delaware Superior Court held that she was not entitled to benefits.

Nemours did not dispute that the vaccination occurred during the course and scope of the nurse’s employment. The court found that the nurse did not establish that her injury was caused by the flu shot. An examining doctor said that the box incident would be compatible with producing a bursitis. The doctor opined that the nurse’s continued symptoms were not related to the flu shot. The doctor also testified about how injections are typically performed and the type of needle that he normally uses. The doctor explained that the tear was on the bursal surface and that supported his opinion that the nurse’s symptoms were from a separate injury.

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The nurse argued that her physician’s testimony supported a finding that her shoulder injuries were caused by the flu injection. She asserted that the injection was given in a place higher than normal. The court found that the arguments seemed to require it to reweigh the evidence already weighed by the Industrial Accident Board.

Attorney’s ‘Networking’ Doesn’t Make Motorcycle Accident Compensable

Westerhof v. State of Wisconsin Labor and Industry Review Commission, No. 2012AP2332 (Wis. Ct. App. 05/22/14, unpublished)

Ruling: In an unpublished decision, the Wisconsin Court of Appeals held that an attorney was not entitled to benefits for injuries sustained in a motorcycle accident.

What it means: In Wisconsin, a worker’s injuries sustained during a social outing with friends who occasionally did business together are not compensable.

Summary: An attorney and shareholder for a law firm was paid based on his “actual work performed” and “clients brought into the firm.” In an effort to market himself, he joined a poker group comprised of small business owners. The group referred clients to each other. The law firm reimbursed the attorney for snacks or drinks he brought to the weekly poker event and for expenses arising from trips he took with poker group members. One of the group members was sued in small claims court, and the attorney filed an answer on his behalf. The attorney asked to join the group member at a motorcycle rally. While riding to the rally, the attorney lost control of his motorcycle and crashed, rendering him a quadriplegic. He sought workers’ compensation benefits, claiming that the injury arose out of his employment because he was “networking” on behalf of the firm. The Wisconsin Court of Appeals held that he was not entitled to benefits.

The court found that the motorcycle trip was not incidental to any asserted business purpose. The trip was not an event initiated by the attorney to entertain a client. Rather, he was a guest on a personal trip initiated and planned by the poker group member.

The court pointed out that the business generated by the attorney from the poker games was minimal. Even if the poker games could be considered client entertainment, it did not follow that every trip taken by the attorney and a poker group member together was client entertainment or business networking.

Worker’s Alleged Negligent Driving Doesn’t Block Benefits

Janiec v. Arko Express, LLC, 28 MIWCLR 30 (Mich. W.C.B.M. 2014)

Ruling: The magistrate awarded benefits to a worker for injuries sustained when the tractor-trailer he was driving tipped over.

What it means: To bar benefits under the “intentional and willful misconduct” provision for a worker’s violation of company policy, the employer must prove the worker’s injury “flowed directly and predictably” from the worker’s policy violation. The provision is not meant to bar benefits to a worker for negligent actions that led to his injuries.

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Summary: The magistrate awarded benefits to a worker for injuries sustained when the tractor-trailer he was driving tipped over. The magistrate rejected the employer’s argument that the worker should be barred from benefits because he intentionally and willfully engaged in misconduct by driving too fast for the road conditions. The employer inferred that the worker’s negligent driving was intentional and willful. The employer’s argument went against the entire purpose of the workers’ compensation law, which is no-fault legislation.

As for the issue of disability, the magistrate found the worker’s testimony regarding the incident, the physiologic responses he developed as a result, his medical treatment, coupled with the testimony of his doctor, established that as a result of the motor vehicle accident, the worker sustained a large, left-sided herniation which displaced the nerve root, causing radiculopathy and discogenic low back pain, resulting in the necessity for physical restrictions. The worker also established disability and that he sustained wage loss.

Provision of Transportation Allows Comp for Worker’s Bus Injury

Skoff v. U.S. Airways, Inc., No. COA13-994 (N.C. Ct. App. 06/03/14)

Ruling: The North Carolina Court of Appeals held that a flight attendant’s injuries were compensable.

What it means: In North Carolina, under the provision of transportation exception to the coming and going rule, an injury during travel arises in the course of employment where the employer furnished the means of transportation as an incident to the contract of employment.

Summary: A flight attendant for U.S. Airways boarded an employee shuttle bus that was so crowded she had to stand to travel from the terminal to the employee parking lot. The bus driver braked suddenly during the trip, causing the flight attendant to fall forward. A piece of luggage hit her, and another airport employee fell on top of her. The flight attendant sustained injuries to her neck and shoulder that required medical treatment. She sought benefits. U.S. Airways denied her claim. The North Carolina Court of Appeals held that she was entitled to benefits.

The court found that the provision of transportation exception to the coming and going rule applied. U.S. Airways provided parking at the airport employee parking lot, furnished its employees with parking passes, and paid the parking fees to the airport as an incident to the flight attendant’s employment. The flight attendant had the right to use the bus that traveled between the parking lot and the terminal.

U.S. Airways asserted that it did not require flight attendants to ride the bus. However, evidence showed that it was a benefit to both U.S. Airways and employees and was approved by U.S. Airways as the “recognized, customary, and habitual way, if not the only or exclusive way” for flight attendants to travel between the parking lot and terminal. The court said that the use of the buses was implied in the assignment of parking passes, and these privileges were considered a matter of right for the employees.

Difficulty Determining Employment Contract Origin Ends Claim

Franco-Lopez v. Martinez, No. WD76942 (Mo. Ct. App. 06/03/14)

Ruling: The Missouri Court of Appeals held that it did not have jurisdiction over a worker’s claim.

What it means: Missouri has jurisdiction of workers’ compensation claims for injuries received out of state under a contract of employment made in the state.

Summary: A worker performed carpentry, construction, and framing work for his employer. He lived with the employer, who was married to his sister, in Missouri. He went with the employer to a home improvement store in Missouri to purchase materials for a roofing project in Kansas. While working on the project in Kansas, the worker fell off the roof and broke his left arm and pelvis. He received temporary disability benefits and medical aid under the Kansas workers’ compensation law. He continued to suffer pain that affected his ability to work. He filed a workers’ compensation claim in Missouri. The Missouri Court of Appeals held that it did not have jurisdiction over the worker’s claim.

The court rejected the worker’s argument that he formed a contract of employment with the employer in Missouri. While the court recognized that the worker lived in Missouri, he had to present other evidence that he and the employer intended to make a contract in Missouri.

The worker said that he went to a hardware store in Missouri on multiple occasions for the project in Kansas. On at least one occasion, the worker was given the employer’s credit card to buy supplies. The worker later drove the supplies to Kansas.

The court pointed out that the worker failed to provide receipts or records regarding the purchases. He did not testify that the employer wanted the materials purchased in Missouri even though the project was in Kansas or that purchasing the materials was a precondition of his employment. The worker was also unable to provide the date he drove from Missouri to Kansas or the date he began working on the Kansas project. The court said it was difficult to determine where the contract was formed.

Medical Expert’s General Opinion Fails to Establish Causation

Barrett v. Dominion Resources Services, No. 1945-13-2 (Va. Ct. App. 06/03/14)

Ruling: The Virginia Court of Appeals held that a worker was not entitled to benefits for his cellulitis.

What it means: In Virginia, a medical expert’s opinion that addresses causation in overly general terms may not establish that a condition of the worker’s employment caused his injury.

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Summary: A worker for Dominion Resources Services was fixing a leaky pump seal over two days. The job required six hours of kneeling and squatting on a concrete floor. The floor was not wet, but the leak had left a film of dirt from muddy water on the floor. On the second day of working on the pump, the worker felt pain in his right knee. He later discovered that his knee was swollen and there was “one small little dot” at the center of the swelling. A few days later, he sought treatment and was diagnosed with cellulitis. His treating physicians never determined the exact cause of the cellulitis. The worker sought benefits. The Virginia Court of Appeals held that he was not entitled to benefits.

The court found that the worker did not establish that any condition of his employment caused his cellulitis. No treating physician linked his cellulitis to his work conditions. A medical expert concluded that the worker’s cellulitis could have been caused by working on his knees. However, the medical expert had never examined the worker, never spoke with him, and never identified any specific pathogen. The Workers’ Compensation Commission had found that the medical expert’s report addressed causation in overly general terms.

Christina Lumbreras is a Legal Editor for Workers' Compensation Report, a publication of our parent company, LRP Publications. She can be reached at riskletters@lrp.com
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View From the Bench

Workers’ Comp Docket

Significant workers' comp legal decisions from around the country.
By: | August 22, 2014 • 11 min read
Docket

Surveillance Video Doesn’t Establish That Nurse Committed Fraud

Our Lady of the Lake Hospital, Inc. v. Johnson,No. 2013CA1314 (La. Ct. App. 06/06/14)

Ruling: The Louisiana Court of Appeal held that a nurse did not commit fraud in obtaining workers’ compensation benefits.

What it means: In Louisiana, a worker’s benefits are forfeited if she willfully made a false statement or representation for the purpose of obtaining benefits.

Summary: A licensed practical nurse was injured in the course and scope of her employment for a hospital when she received an electric shock while plugging in a laptop computer. As a result of the accident, she developed complex regional pain syndrome. She was also diagnosed with post-traumatic stress disorder. The hospital paid benefits. The hospital reduced her supplemental earnings benefits. Later, the hospital alleged that the nurse made false statements or representations for the purpose of obtaining workers’ compensation benefits. The nurse sought penalties and attorney’s fees. The Louisiana Court of Appeal held that the nurse did not commit fraud.

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The hospital asserted that the nurse exaggerated her symptoms once she started recovering in order to continue receiving benefits. Surveillance footage showed the nurse going about her daily life without her hand brace and using her right hand. The court found that the nurse did not commit fraud. She and her husband testified that she had good days and bad days, she did not always wear her brace, and she attempted to use her right hand as a “helper” hand. The court found the surveillance video did not conflict this testimony.

A vocational counselor learned of a potential job as a medical transcriptionist with the hospital. The hospital offered the job with accommodations, but the nurse declined because the hospital would not hold the job for her until after she had a baby. The hospital asserted that it was justified in reducing the nurse’s benefits. The court disagreed, finding that the job was not suitable regarding the nurse’s limitations and the amount of travel required for the job.

The court also rejected the nurse’s request for penalties and attorney’s fees.

Player Can’t Score Benefits for Injury During Minicamp Tryout

Robinson v. Department of Labor and Industries, et al.,No. 69739-1-I (Wash. Ct. App. 05/27/14)

Ruling: The Washington Court of Appeals held that a free agent football player was not entitled to benefits because he was not an employee of the team.

What it means: In Washington, an employment relationship exists when the employer has the right to control the worker’s physical conduct in the performance of his duties and there is consent by the worker to the relationship.

Summary: A football player, who was a free agent, was invited to attend a three-day minicamp tryout for the Seattle Seahawks. The team paid his travel expenses. The player signed a waiver and release of liability that stated he was not an employee of the team and released the team from liability for injury.

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During an on-field drill, the player injured his knee as he dove for the ball. The team trainer diagnosed a torn meniscus. The player sought workers’ compensation benefits. The Washington Court of Appeals held that he was not entitled to benefits because he was not an employee of the team.

The court found there was not an implied contract of employment between the player and the team. The team did not have the right to control the player’s physical conduct in the performance of his duties. Participation in the minicamp was voluntary and the on-field drills were different from preseason training or a game.

The player attended the minicamp in the hopes that the team would offer him a contract. Successful completion of the minicamp tryout did not guarantee employment with the team. The court also found there was no mutual agreement to an employment relationship between the player and the team, and no evidence supported a reasonable belief that he was an employee. The player had previously tried out for two other teams but had not been offered employment.

Although the player asserted that the team paid his travel expenses, the court said the statute defining wages was not applicable.

Attendant Care Required to Prevent Deterioration of Worker’s Condition

Alabama Forest Products Industry Workmen’s Compensation Self Insurer’s Fund v. Harris,No. 2121008 (Ala. Civ. App. 06/13/14)

Ruling: The Alabama Court of Civil Appeals held that an employer was required to pay attendant care expenses for a worker.

What it means: In Alabama, an injured worker is entitled to attendant care if because of his injury, attendant care is reasonably necessary to improve his condition, to prevent the deterioration of his condition, or to relieve him of the adverse effects of his injury on his ability to function.

Summary: A worker suffered severe injuries to his pelvis and right lower extremity in a work-related accident. His employer’s insurer, Alabama Forest Products, paid various members of his family a monthly stipend to assist him, as instructed by his treating physician. The worker settled his workers’ compensation claim against his employer, and Alabama Forest Products continues to pay a monthly sum to various members of his family for attending to him for the next 20 years. Later, the worker sent notice to the third-party administrator that he wanted his future son-in-law to replace his daughter as his designated caregiver. When the TPA discovered that the son-in-law was employed full time out of the town where the worker lived, it terminated payments for attendant care. The Alabama Court of Civil Appeals held that Alabama Forest Products was required to pay attendant care expenses.

Due to the severity of his injuries, the worker regularly required assistance with the ordinary activities of daily living. He needed help performing his leg exercises, taking his medication, applying medicine to his injured areas, and preventing bedsores. The worker’s physician said that attendant care services would prevent the deterioration of his physical condition and that he considered attendant care reasonably necessary medical attention and physical rehabilitation. The court explained that the worker did not have to further prove that the attendant care would actually improve his physical condition.

The court also said that the fact that the worker retained some limited mobility and function such that he did not require constant monitoring and attendance did not change its decision. The worker ordinarily received attendant care throughout the day and always kept his telephone nearby in case he needed help from a family member who lived moments away.

Employer Must Provide Wheelchair-Accessible Van to Worker

Simmons v. Precast Haulers, Inc.,No. S-13-848 (Neb. 07/03/14)

Ruling: The Nebraska Supreme Court held that a worker was entitled to a wheelchair-accessible van and payment for the in-home care provided by his wife.

What it means: In Nebraska, a wheelchair-accessible van can be a medical “appliance” that will help restore the worker’s health.

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Summary: A worker for Precast Haulers sustained extensive injuries when he was run over by a fully loaded tractor-trailer. Precast conceded that the worker’s injuries and his medical bills were compensable but asserted that he was not entitled to a wheelchair-accessible van and payment for the in-home care provided by his wife. The worker’s doctors recommended that he receive custom wheelchairs and a wheelchair accessible van. The worker required 24-hour in-home nursing care. His wife took over his care for 108 hours per week. The Nebraska Supreme Court held that the worker was entitled to the van and payment for the in-home care provided by his wife.

In a case of first impression, the court found that a wheelchair-accessible van was an “appliance” that would help restore the worker’s health. His treating physicians opined that a van would assist in his outpatient recovery and rehabilitation. No evidence from the physicians showed that the worker could not or should not drive. The court found that the van was necessary to allow the worker and his family to transport his new powered wheelchair.

Precast asserted that many of the hours spent by the worker’s wife “on call” were spent sleeping, completing ordinary household duties, and caring for herself. The court pointed out that a paid third-party nurse might read, nap, or perform household tasks and would be compensated for that time. The court found Precast knew the worker needed assistance and there was a means of determining the reasonable value of services rendered by the wife. The wife completely replaced the care of the night and weekend nurses.

Taxi Driver Picks up Benefits for Injury While Traveling Home in Cab

Fahmi, 114 NYWCLR 68 (N.Y.W.C.B., Panel 2014)

Ruling: The New York Workers’ Compensation Board held that a taxi driver, who was driving the employer’s taxi home upon the employer’s instruction due to a post-hurricane gas shortage, sustained injuries arising out of his employment when he was assaulted and robbed after exiting the vehicle.

What it means: In New York, where a worker is injured while performing a special errand for the benefit of the employer, and the employer encouraged the errand, the worker is entitled to portal-to-portal workers’ compensation coverage.

Summary: A taxi driver, who was driving the employer’s taxi home upon the instruction of the employer due to a post-hurricane gas shortage, sustained injuries when he was assaulted and robbed after exiting the vehicle. The board held that the driver’s injuries arose out of and in the course of his employment. The board explained that a worker is entitled to workers’ compensation while performing a special errand for his employer, provided the employer encouraged the errand and obtained a benefit from the worker’s performance of the errand. The evidence established that the driver was performing an errand for the benefit of the employer at the time of the injury and therefore was entitled to portal-to-portal coverage.

Treating Physicians’ Opinions Not Assigned Greater Weight Than Other Physicians

Estate of Cleveland v. Heritage Properties, Inc.,No. 2013-WC-00451-COA (Miss. Ct. App. 06/10/14)

Ruling: The Mississippi Court of Appeals held that a manager’s mental injury and death were not compensable.

What it means: In Mississippi, the testimony of a worker’s treating physicians’ opinions is not required to be given more weight than the employer’s examining physicians.

Summary: An apartment manager for Heritage Properties was injured when a filing cabinet allegedly fell on her. She filed for disability benefits for a closed head injury and a mental injury. While her claim was pending, she died of a drug overdose. Her mother sought death benefits. Heritage and its carrier admitted a physical injury but contested a physical impairment after the neurosurgeon found the manager reached maximum medical improvement. Heritage and its carrier also disputed liability for the manager’s mental injury and death. The Mississippi Court of Appeals held that the manager’s mental injury and death were not compensable.

The court rejected the mother’s argument that the manager’s treating physicians’ opinions should be given greater weight than Heritage’s examining physicians. The court also pointed out that the treating physicians lacked complete medical records and proper medical histories of the manager’s lengthy drug, alcohol, sexual, psychological, and physical abuse. The court also said the fact that a doctor examines a patient once does not render his examination inadequate or incomplete. The court pointed out that a doctor who examined the manager once was one of four doctors who found no causal relationship between the work incident and the claimed injuries.

The court found that the manager’s preexisting psychological issues rather than the alleged work injury led to her increased dependence on a destructive relationship and substance abuse.

No Coverage for Depression Caused by Reaction to Perceived Events

White v. Valley Youth House Committee Inc.,29 PAWCLR 69 (Pa. W.C.A.B. 2014)

Ruling: The Pennsylvania Workers’ Compensation Appeal Board reversed the workers’ compensation judge’s decision granting the claim petition of a counselor who alleged that he sustained depression during the course and scope of his employment.

What it means: In Pennsylvania, a worker’s depression that is a result of a subjective reaction to perceived events is not sufficient to establish that he was subjected to abnormal working conditions.

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Summary: The board reversed the WCJ’s decision granting the claim petition of a counselor for troubled youth who alleged that he became depressed and stopped working after receiving letters which appeared to confirm that another counselor was acting inappropriately with a female client at the employer’s facility. The counselor explained that he brought the matter to the attention of his supervisor but the supervisor did not do anything about it. He stated this made him depressed because he did not feel as though he was doing a good job protecting the kids. In reversing, the board noted that the counselor acknowledged he never worked with the other counselor, and he did not actually witness the other counselor and the client acting inappropriately with each other. Also, the supervisor testified that the counselor’s concerns were addressed.

The board concluded that the counselor’s depression was the result of a subjective reaction to inappropriate behavior he perceived to have taken place and the employer’s perceived lack of action regarding that behavior. The counselor’s reaction to perceived events was not sufficient to establish that he was subjected to abnormal working conditions.

Christina Lumbreras is a Legal Editor for Workers' Compensation Report, a publication of our parent company, LRP Publications. She can be reached at riskletters@lrp.com
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