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Case name: Daniels v. Wausau Business Ins. Co., No. 2009AP2590 (Wis. Ct. App. 12/28/10, unpublished).

Ruling: In an unpublished decision, the Wisconsin Court of Appeals held that work-related stress was not causally related to a jailer's ruptured brain aneurysm that occurred at work.

Summary: A 72-year-old jailer suffered a ruptured brain aneurysm while at work. In the weeks prior to the rupture, he claimed he was under stress due to concerns that scheduling changes would result in the elimination of his job. Before the rupture, he spoke to his supervisor about his concerns. He was angry when he arrived at the supervisor's office, which caused her to cry. She assured the jailer that administration was not trying to replace him, so she thought he felt better. After the conversation, he returned to work and spoke with a coworker. The coworker said the jailer was upset and felt bad for making the supervisor cry. They also talked about other subjects, such as what they were going to have for dinner. After talking for approximately 15 minutes, the jailer suddenly collapsed in his chair. He sought benefits. The Wisconsin Court of Appeals held that the jailer was not entitled to benefits because work-related stress was not causally related to the rupture.

Although the jailer's doctor opined that he was experiencing increased stress at work which elevated his blood pressure, causing the rupture, the court said that there was no evidence of raised blood pressure prior to the rupture. Additionally, the evidence supported an inference that the "minimal stress" the jailer was exposed to at work did not reach the level of severity to cause a significant elevation in his blood pressure.

The court also noted the jailer's preexisting conditions, including vasculopathic disease, hypertension, a history of heavy smoking, and his father's death by an aneurysm.

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February 17, 2011

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