Armstrong v. John R. Jurgensen Co.
136 Ohio St. 3d 58
| Ohio | 2013Background
- Armstrong, employed by Jurgensen Co., was in a motor-vehicle crash in the course of employment on Aug. 27, 2009.
- Armstrong sustained compensable physical injuries (cervical, thoracic, and lumbar strains).
- Armstrong developed posttraumatic-stress disorder (PTSD) contemporaneously with the accident.
- Industrial Commission staff granted PTSD as an additional allowance; employer appealed to the IC, which denied the appeal.
- Trial court conducted bench trial after stipulation that Armstrong has PTSD; expert testimony on causation was adduced.
- The court of appeals affirmed, holding PTSD not compensable absent a causal link to the physical injuries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether R.C. 4123.01(C)(1) requires a causal link between a compensable physical injury and a psychiatric condition. | Armstrong argued PTSD is compensable if contemporaneous with the injury. | Jurgensen contends PTSD must be caused by the physical injury, not merely contemporaneous. | Causation required; PTSD must arise from the compensable physical injury. |
| Effect of the 2006 amendment adding 'arisen from' language to R.C. 4123.01(C)(1). | Amendment clarifies that contemporaneous injury can support compensation. | Amendment does not alter the nexus requirement; must be causal to the physical injury. | Amendment did not change the necessity of a causal link to the physical injury. |
| Whether contemporaneous PTSD arising from an accident without a direct causal link to physical injuries is compensable. | Contemporaneous psychic injury should be compensable if linked to the accident. | Compensation requires a causal connection to a compensable physical injury. | Contemporaneous PTSD without causal link to physical injuries is not compensable. |
Key Cases Cited
- McCrone v. Bank One Corp., 107 Ohio St.3d 272 (2005-Ohio-6505) (psychiatric conditions require causal link to physical injury; equal-protection context)
- Bailey v. Republic Engineered Steels, Inc., 91 Ohio St.3d 38 (2001) (psychiatric condition arising from an injury to a third party is compensable)
- Rambaldo v. Accurate Die Casting, 65 Ohio St.3d 281 (1992) (establishes limits on dynamic scope of 'injury' in workers’ comp)
- Fisher v. Mayfield, 49 Ohio St.3d 275 (1990) ('arising out of' contemplates causal connection)
- Dunn v. Mayfield, 66 Ohio App.3d 336 (1990) (mental/physical injury nexus required for compensability in the appellate context)
- Bunger v. Lawson Co., 82 Ohio St.3d 463 (1998) (psychiatric conditions with/without physical injury discussed in scope of coverage)