Pennsylvania Supreme Court holds that a Pennsylvania state trooper who struck and killed a woman with his patrol car was entitled to benefits for a psychic injury due to abnormal working conditions.
The claimant, a trooper for the Pennsylvania State Police, was driving his patrol car early on a dark morning when a woman, dressed all in black, suddenly ran in front of his vehicle and was struck by the car. The claimant immediately pulled the car into the traffic lane and rushed to help the woman. Although the claimant tried mouth-to-mouth resuscitation and diverted oncoming traffic, the woman was pronounced dead at the scene. Later, it was discovered that she suffered from a mental illness and had been seen by several drivers walking up and down the area next to the highway where the incident occurred.
The claimant attempted to return to work but was not able to do so because of recurring feelings of anxiousness and stress. The claimant filed a claim petition alleging that he suffered from Post-Traumatic Stress Disorder as a result of the incident.
The claim petition was granted by the Workers’ Compensation Judge, who found that the claimant had proven a mental injury arising from a work-related mental stimulus. The judge further found that, although state troopers may expect to be involved in violent situations, this particular one was very unusual. Consequently, the judge found that this was an abnormal working condition.
However, the judge’s decision was reversed by the Appeal Board, and their decision was affirmed by the Commonwealth Court. In its opinion, the court stated, “Indeed, it is not beyond the realm of possibility for an officer to have to take someone’s life.” The court also said that, although the events may have been unusual, they were not so much more stressful and abnormal than the already stressful nature of the claimant’s job.
The Pennsylvania Supreme Court reversed the Commonwealth Court’s decision and held that the claimant was entitled to benefits for a mental injury caused by abnormal working conditions. Noting that psychic injury cases are “highly fact sensitive,” the Court pointed out that this does not mean that an abnormal working conditions analysis ends when it is established that a claimant generically belongs to a profession that involves certain levels of stress. According to the Supreme Court, the Commonwealth Court erred by not accepting the well-supported facts found by the judge establishing the existence of an extraordinarily unusual and distressing single work event experienced by the claimant, resulting in his disabled mental condition. In the Court’s view, such an event constituted an abnormal working condition as a matter of law.
Case Law Alert, 1st Quarter 2014