Hoelscher v. KBO, Inc., 2017 Ohio 5756

In 2012 Hoelscher injured his ankle at work and received workers’ compensation for ankle injuries.
He was fired in 2013, later medically released in 2014, retrained as an HVAC technician, and briefly worked before a layoff.
In mid‑2015 Hoelscher was diagnosed with several psychiatric conditions (panic disorder, generalized anxiety, major depressive disorder, adjustment disorder, depressed mood).
Hoelscher sought to amend his workers’ compensation claim to add those psychiatric conditions; the BWC denied the amendment, concluding no causal link to the 2012 injury, and the Industrial Commission refused review.
In the court of common pleas KBO moved for summary judgment supported by Dr. Tosi’s opinion that the psychiatric conditions were too remote from the 2012 injury and were caused by later job termination/layoff; Hoelscher opposed with Dr. Barwick’s opinion linking the psychiatric conditions to the 2012 injury.
The trial court granted summary judgment for KBO; the appellate court considered whether a genuine factual dispute exists about causal connection and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether psychiatric conditions “arose from” the 2012 work injury so as to be compensable under the Ohio Workers’ Compensation Act	Hoelscher: psychiatric diagnoses are causally connected to the 2012 ankle injury	KBO: the psychiatric conditions are too remote from the 2012 injury and were caused by later employment events (firing/layoff)	Reversed trial court: genuine factual dispute exists about causation, so summary judgment for KBO was improper

Armstrong v. John R. Jurgensen Co., 136 Ohio St.3d 58 (Ohio 2013) (statute requires a causal connection between a claimant’s physical injury and a psychiatric condition)
State ex rel. Parsons v. Flemming, 68 Ohio St.3d 509 (Ohio) (summary judgment standard)