Case name: Mazzone v. Texas Roadhouse, Inc., No. 39337, 2013 Opinion No. 55 (Idaho 04/26/13).
Ruling: The Idaho Supreme Court held that a restaurant worker was not entitled to benefits for his psychological injuries after he sustained a work-related burn injury.
What it means: In Idaho, a physical-mental claim is compensable when the accident and physical injury is the predominant cause of the psychological injury.
Summary: A restaurant worker suffered a severe burn on his arm after he tripped and plunged his arm into a deep fat fryer. He claimed that he began to suffer from nightmares, night tremors, and flashbacks after the incident. His global assessment of functioning score after the accident was the same as it was before the accident. The worker was later diagnosed with depression, generalized anxiety disorder, memory loss, panic attacks, and post-traumatic stress disorder. The worker sought benefits for his psychological condition. The Idaho Supreme Court held that he did not suffer a compensable psychological condition.
The court found that the worker did not suffer from a psychological condition resulting from an industrial accident. The court credited the testimony of a doctor who found the worker did not suffer from PTSD. The doctor personally examined him, administered psychological testing, examined his records from his burn injuries, examined his prior psychiatric history, and considered whether he was exaggerating his pain.
The court also concluded that the worker failed to show that the industrial accident was the predominant cause of his alleged PTSD. The worker suffered from stress before the accident and had a history of psychiatric disorders. Two days before the accident, he was evaluated for sleep deprivation, difficulty concentrating, and feelings of being overwhelmed. The court also noted that for two years after the accident his recovery was "very positive" and he was learning coping skills.
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July 29, 2013
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