Injury Cases: Psychiatric (Court of Appeals)

Ohio Workers’ Compensation Decisions
(Court of Appeals)

Injury: Psychiatric

Select the case name to read the decision on the Ohio Supreme Court’s web site. For other issues, see our topic index to Ohio workers’ compensation decisions.

Armstrong v. John R. Jurgenson Co. (12/23/11)

Post-traumatic stress disorder which occurred at the same time worker suffered physical injuries, but which did not arise out of the physical injuries, is not compensable.

Vote: 2-1
Opinion by: Judge Grady
Appellate District: 2

Coleman v. KBO, Inc. (3/2/18)

Length of time between injury and alleged psychological condition does not determine whether condition can be allowed because there is no set time requirement for a physical injury to cause a compensable psychological condition.

Vote: 3-0
Opinion by: Froelich
Appellate District: 2

Ireland v. S. Ohio Correctional Facility (6/22/06)

Psychiatric injury resulting from perception of possible injury to co-worker is not compensable where neither worker suffered any physical harm.

Vote: 3-0
Opinion by: Judge Harsha
Appellate District: 4

Jones v. Catholic Healthcare Partners, Inc. (12/31/12)

Dual causation rule permits worker to participate for post-traumatic stress disorder caused both by stress of being taken hostage and physical injury which occurred to worker during incident.

Vote: 3-0
Opinion by: Judge Waite
Appellate District: 7

Jones v. Med. Mut. of Ohio (2/19/04)

Evidence supported trial court’s finding that work injury was not a cause of claimant’s psychiatric condition.

Vote: 3-0
Opinion by: Judge Celebrezze
Appellate District: 8

Martin v. Pechiney Plastic Packaging (1/15/04)

Mental injury, without physical harm, is not compensable.

Vote: 2-1
Opinion by: Judge Calabrese
Appellate District: 8

McCrone v. Bank One Corp. (5/17/04)

There is no reason to exclude a psychological injury which does arise from a physical injury from workers’ compensation coverage; therefore, the R.C. 4123.01(C)(1) exclusion of psychological injuries is unconstitutional.

Vote: 2-1
Opinion by: Judge Gwin
Appellate District: 5

Munday v. S. Ohio Coal Co. (5/27/04)

Medical testimony which indicated that injury caused “major depression” was sufficient to permit jury to consider workers’ compensation claim even though evidence indicated that injured worker had suffered from depression before injury.

Vote: 2-0
Opinion by: Judge Harsha
Appellate District: 4

Rader v. Fifth Third Bancorp (3/30/10)

A worker who suffered a psychological-only injury after seeing a compensable injury to a third party before the effective date of the 2006 amendments is entitled to participate.

Vote: 3-0
Opinion by: Judge Sadler
Appellate District: 10

Sanden v. Cincinnati (12/21/07)

Police officer who neither saw nor witnessed deaths of co-workers was not entitled to participate in workers’ compensation fund for post-traumatic stress disorder.

Vote: 2-1
Opinion by: Judge Sundermann
Appellate District: 1

Wood v. Ohio State Hwy. Patrol (4/1/04)

Psychiatric injury without physical injury is excluded from workers’ compensation coverage; exclusion of psychiatric-only injury is not unconstitutional.

Vote: 3-0
Opinion by: Judge Wise
Appellate District: 5