Mount v. Bd. of Trs., Police & Firemen's Ret. Sys.
186 A.3d 248
| N.J. | 2018Background
- Two PFRS police-officer applicants sought accidental disability benefits based on PTSD: Officer Christopher Mount (witnessed a car explosion that incinerated three teenagers) and Detective Gerardo Martinez (hostage negotiator who spoke by phone with a suspect who was later shot and killed during a tactical entry).
- Statute (N.J.S.A. 43:16A-7(1)) permits accidental disability where a member is permanently and totally disabled as a direct result of a "traumatic event" occurring during assigned duties; Legislature did not define "traumatic event."
- New Jersey precedent establishes a two-step analysis for purely psychological injuries: Patterson threshold (direct personal experience of a terrifying/horror-inducing event objectively capable of disabling a reasonable person) and, if met, the Richardson test (traumatic event must be identifiable, undesigned and unexpected, external cause, etc.).
- Administrative Board denied accidental benefits to both applicants; Appellate Division affirmed for Mount (holding event expected by job) and reversed for Martinez (finding Patterson and Richardson satisfied). Both matters certified to the Supreme Court.
- Supreme Court held Mount met Patterson and Richardson's undesigned/unexpected requirement (but remanded for unresolved causation evidence), and held Martinez met Patterson but failed Richardson (shooting was not "undesigned and unexpected").
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mount experienced a "terrifying or horror‑inducing" event under Patterson | Mount: witnessing close‑range explosion, smell/vision of burned bodies, and trauma satisfy Patterson | Board: event was within job scope/training and not objectively capable of disabling a reasonable officer | Held: Mount satisfied Patterson (event was terrifying/horror‑inducing) |
| Whether Mount's incident was "undesigned and unexpected" under Richardson | Mount: circumstances (no firefighting gear, extreme close‑range explosion, melted victims) made the event extraordinary and unexpected | Board/App. Div.: such accidents are within policing duties and training, so expected | Held: Event was undesigned and unexpected; Appellate Division reversed on this point; remanded to determine causation |
| Whether Mount proved the disability was the "direct result" of the event (causation) | Mount: identified Jan 10, 2007 incident as the disabling event and claimed PTSD resulting directly from it | Board/ALJ: ALJ found insufficient proof but record lacked medical evidence; Board did not resolve; Appellate Division did not reach it | Held: Causation unresolved on record; remanded to Appellate Division to address with opportunity to supplement evidence if needed |
| Whether Martinez satisfied Patterson and Richardson (i.e., entitled to accidental benefits) | Martinez: twelve‑plus hours of direct phone contact, hearing pleas during shooting, and viewing body satisfy Patterson and were unexpected | Board: experience was direct for Patterson but tactical context, training, and prior signs made the shooting foreseeable (not undesigned/unexpected) | Held: Martinez meets Patterson (direct, horror‑inducing experience) but fails Richardson (shooting was not undesigned/unexpected); Appellate Division reversal reinstated in favor of Board |
Key Cases Cited
- Richardson v. Board of Trustees, PFRS, 192 N.J. 189, 927 A.2d 543 (N.J. 2007) (establishes five‑part test for accidental disability, including "undesigned and unexpected" requirement)
- Patterson v. Board of Trustees, SPRS, 194 N.J. 29, 942 A.2d 782 (N.J. 2008) (adopts horror‑inducing event threshold for purely psychological claims)
- Russo v. Bd. of Trs., PFRS, 206 N.J. 14, 17 A.3d 801 (N.J. 2011) (applies Patterson threshold; considers training and event intensity)
- Kane v. Bd. of Trs., PFRS, 100 N.J. 651, 498 A.2d 1252 (N.J. 1985) (prior three‑part traumatic‑event test criticized and superseded by later standards)
- Cattani v. Bd. of Trs., PFRS, 69 N.J. 578, 355 A.2d 625 (N.J. 1976) (early discussion of "traumatic event" concept)
- Moran v. Bd. of Trs., PFRS, 438 N.J. Super. 346, 103 A.3d 1217 (App. Div. 2014) (example applying Richardson to firefighter who rescued victims under unusual circumstances)
- Thompson v. Bd. of Trs., TPAF, 233 N.J. 232, 184 A.3d 455 (N.J. 2018) (Affirms Patterson threshold exclusion where incidents lacked threat of death or serious injury)