Case name: Scott Colson's Shop, Inc. v. Harris, No. 2010-WC-00363-COA (Miss. Ct. App. 07/19/11).
Ruling: The Mississippi Court of Appeals held that a machinist was not entitled to benefits for his schizophrenia.
What it means: In Mississippi, a worker claiming a mental injury stemming from a mental stimulus must show the injury was caused by something more than the ordinary incidents of employment.
A machinist, who made horseshoes in a blacksmith shop, claimed that his supervisor began harassing him on his second day of work. He said the supervisor used racial slurs and had barbeques at the shop for only white employees. The shop's new owner apologized on behalf of the supervisor, but the machinist stopped going to work after six months. Over time, the machinist became increasingly paranoid. His treating physicians noted that the work incidents figured heavily into his mental state. The machinist was afraid that the supervisor or former owner of the shop would try to kill him. One year after he left the shop, he was diagnosed with severe, chronic paranoid schizophrenia. Six years later, he was completely disabled as a result of his mental condition. He sought benefits, claiming that the racially hostile environment at the shop caused him to develop schizophrenia. The Mississippi Court of Appeals held that he was not entitled to benefits.
The court noted that there was no evidence that the machinist had a history of mental illness before he worked for the shop. There was also no evidence that he had a preexisting condition that was aggravated by his employment. The court pointed out that it was disputed whether there was a racially hostile environment at the shop.
The court found that the machinist did not show a causal connection between his schizophrenia and his work. None of his treating psychiatrists mentioned a causal connection. The shop's doctor explicitly stated that there was no causal connection.
A dissenting judge thought it should be considered whether the machinist suffered from a mental illness during his employment at the shop and whether it was exacerbated by the incidents at the shop.
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August 29, 2011
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