In a physical/mental injury claim, a claimant need not prove that a physical disability caused a mental disability nor show that a physical injury continues during the life of the psychic disability.

The claimant was employed as an equipment operator and was involved in a work-related accident while operating a tractor trailer. The tractor trailer collided head on with another vehicle, and the claimant observed the driver of the oncoming vehicle looking directly at him at the time of impact. The driver of the other vehicle died as a result of the accident. The collision forced the claimant's truck down an embankment. The claimant was eventually taken to the emergency room of a local hospital and diagnosed with injuries to the left chest, right wrist and left shoulder.

The claimant continued to work for the employer. Initially, the claimant did not drive, since his trailer was destroyed. Ultimately, the claimant resumed his pre-accident duties, but, within a few months, the claimant began receiving treatment for post-traumatic stress disorder. After missing some time from work, the claimant returned to the employer as a laborer at a lower weekly wage.

The claimant filed a claim petition, alleging he sustained PTSD as a result of the motor vehicle accident. The Workers' Compensation Judge granted the petition, concluding that the claimant had met his burden of proving a physical/mental injury that resulted from a "triggering physical event." The Board affirmed.

On appeal to the Commonwealth Court, the employer argued that the Board erred by applying the standard for a physical/mental injury as opposed to a mental/mental injury. The Commonwealth Court, however, rejected the employer's argument and affirmed the decisions below. The court held that the claimant did meet his burden of proving a physical/mental injury and concluded that the physical/mental analysis was properly applied by the judge and was supported by substantial evidence. The court further concluded that the mental/mental standard was inapplicable because, in other mental/mental cases, physical stimulus was not the cause of psychological injury.

Case Law Alerts - 2nd Quarter 2013