Failure to link PTSD to single stressful event derails teacher's claim
Case name: Delrie v. Peabody Magnet High School, No. WCA 10-40 (La. Ct. App. 06/02/10).
Ruling: Because a teacher failed to show that her mental injury was caused by a sudden unexpected event, she was not entitled to collect workers' compensation benefits, the Louisiana Court of Appeal held. Two experts agreed that the teacher's condition was caused as much by what happened after the incident as the incident itself.
What it means: In Louisiana, mental injuries resulting from work-related stress are not compensable unless they are caused by a sudden, unexpected and extraordinary event. A mental injury that results from events that occur over an extended period of time will not justify an award of benefits.
During the middle of class, a student entered the classroom of a home economics teacher, claiming that people were shooting inside the school. The student pretended to be upset and attempted to hide. After five to 10 minutes, the student admitted the event was a hoax. The teacher reported the student's actions, which led to his expulsion. During the weeks that followed, she felt physically threatened by her students, who blamed her for the expulsion of their classmate. She also said she was not supported by the staff, which made fun of her. The teacher began to experience feelings of depression and impending doom and stopped reporting to work. She filed a workers' compensation claim for post-traumatic stress disorder. The court upheld the dismissal of the claim.
The teacher claimed that her condition resulted from the student's hoax. Her entitlement to benefits turned on whether she could link her PTSD to that incident. Although she may have found the event to be extraordinary and violent, the court concluded that the student's practical joke -- while unfortunate -- was not an extraordinary event in the course of a high school teacher's employment.
Two psychologists indicated that the teacher was more susceptible to PTSD because she had a history of emotional and physical violence. They explained that the PTSD was more likely the result of a culmination of events, beginning with the hoax and continuing over the next two weeks. Although the teacher experienced PTSD, she was not entitled to benefits because her condition was the result of a combination of events rather than from the hoax alone.
Read more at the WorkersComp Forum homepage.
August 12, 2010
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