Stressful working conditions typical for teacher, not compensable

To recover workers' compensation for a mental injury in South Carolina, an employee must show that she was exposed to unusual and extraordinary conditions in her employment.

Case name: Tennant v. Beaufort County School District, No. 26616 (S.C. 03/16/09).

Ruling: The South Carolina Supreme Court held that a special education teacher was not entitled to workers' compensation benefits for her alleged mental injury.

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What it means: To recover workers' compensation for a mental injury in South Carolina, an employee must show that she was exposed to unusual and extraordinary conditions in her employment, and that these conditions were the direct cause of her mental disorder.

Summary: A teacher experienced a panic attack as a result of a stressful situation with two new aides. After an argument with the aides, the teacher felt faint and went to the nurse's office, where she was informed that her blood pressure was elevated. A physician diagnosed her with a stress reaction. The district contested her workers' compensation claim, noting that conflicts like the one between the teacher and the aides, which triggered her symptoms, were not unusual or out of the ordinary for her type of work.

A treating social worker diagnosed her with post-traumatic stress disorder and continued panic attacks and recommended that she not return to work. However, the social worker also conceded that panic attacks may be triggered absent unusual or extraordinary circumstances. The district's medical expert disputed both opinions, concluding instead that the teacher suffered a single anxiety attack but was capable of returning to work without further treatment.

The teacher admitted that being a special education teacher is an inherently stressful job. Noting that neither the teacher's supervisor nor her aides threatened her or physically injured her, the court reasoned that while stressful, the triggering event was not an unusual or extraordinary circumstance, and the teacher did not suffer a compensable injury. The court said that the teacher did not demonstrate that she was exposed to unusual and extraordinary conditions in her employment or that the conditions were the proximate cause of her mental disorder.

April 13, 2009

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