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The Supreme Court of Ohio Rules on Workers Compensation Coverage for Mental Health Conditions

The Supreme Court of Ohio’s decision in Armstrong v. John R. Jurgensen Co. restricts workers’ rights to receive workers’ compensation for serious mental conditions resulting directly from their jobs. Under the ruling, a worker is entitled to compensation if the mental illness was caused by a physical workplace injury or occupational disease, such as a stress-related heart attack or depression triggered by brain damage. However, psychiatric conditions that arise from a workplace incident or stress are not covered.

Armstrong v. John R. Jurgensen Co. was decided in June 2013 and involved a 2009 work-related traffic accident. Shaun Armstrong was driving a dump truck for the John Jurgensen Company. While he was stopped, another motorist slammed into the back of his truck at a high speed. Armstrong was treated for his physical injuries and released from the hospital, but suffered distress when he learned that the other man died.

Armstrong filed a claim for cervical strain, thoracic strain and lumbar strain, and subsequently for posttraumatic stress disorder (PTSD), a psychological condition manifesting in a heightened, dangerous level of flight-or-fight response triggered by a traumatic event.

Initially, the Bureau of Workers’ Compensation (BWC) allowed Armstrong’s additional PTSD claim, a decision that was appealed by his employer. Eventually, the case made it to the Supreme Court of Ohio. The court ruled that “Armstrong’s physical injuries did not cause his PTSD and that Armstrong’s PTSD is, therefore, not a compensable injury.”

Proving the relationship between a physical injury and mental condition is, therefore, a crucial component of workers’ compensation recovery in Ohio for a psychological condition.

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