Mantia v. Missouri Department of Transportation
529 S.W.3d 804
Mo.2017Background
- Mantia worked >20 years for Missouri DOT as a crew leader/supervisor responding to highway accident scenes, including fatalities.
- Beginning in 2008 she sought treatment for depression and PTSD-like symptoms and saw psychiatrists/therapists intermittently.
- In Oct. 2008 Mantia filed a workers’ compensation claim for a mental injury allegedly caused by work-related stress.
- The ALJ denied benefits, finding Mantia failed to prove the stress was "extraordinary and unusual" under § 287.120.8, relying on testimony that witnessing tragic scenes is common for highway workers.
- The Labor and Industrial Relations Commission reversed, awarding 50% permanent partial disability and future medical care.
- The Supreme Court vacated and remanded, holding the Commission failed to apply the statutory objective standard for extraordinary and unusual work-related stress.
Issues
| Issue | Mantia's Argument | Missouri DOT's Argument | Held |
|---|---|---|---|
| Whether Mantia met § 287.120.8 by proving her mental injury resulted from "work-related" and "extraordinary and unusual" stress measured by objective standards and actual events | Mantia relied on her testimony and treating expert opinions that her depression/PTSD were caused by workplace incidents | DOT argued the stress encountered was not extraordinary or unusual for highway workers and that the Commission failed to apply an objective standard; evidence was insufficient | Court held the Commission failed to apply the required objective standard (what a reasonable highway worker would experience under same/similar events); vacated and remanded for proper application of that objective test |
Key Cases Cited
- Greer v. SYSCO Food Servs., 475 S.W.3d 655 (Mo. banc 2015) (standards for reviewing Commission decisions)
- Hampton v. Big Boy Steel Erection, 121 S.W.3d 220 (Mo. banc 2003) (whole-record sufficiency review)
- Malam v. State, Dep’t of Corr., 492 S.W.3d 926 (Mo. banc 2016) (de novo review of legal questions)
- Templemire v. W & M Welding, Inc., 433 S.W.3d 371 (Mo. banc 2014) (statutory interpretation principles)
- Hodges v. Am. Bakeries Co., 412 S.W.2d 157 (Mo. banc 1967) (external/objective legal standards)
- Schaffer v. Litton Interconnect Tech., 274 S.W.3d 597 (Mo. App. S.D. 2009) (comparing claimant stress to similarly situated employees)
- Carnal v. Pride Cleaners, 138 S.W.3d 155 (Mo. App. W.D. 2004) (objective comparison to others in same position)