Muhammad v. District of Columbia Department of Employment Services
2012 D.C. App. LEXIS 3
| D.C. | 2012Background
- Mr. Muhammad sustained a compensable back injury on March 1, 2002 while working for Eastern Electric, Inc.
- Three years later he entered vocational rehabilitation due to his new sedentary work limitations and limited transferable skills.
- Psychiatric evaluation in 2006 diagnosed a mental illness linked to the 2002 injury, with treatment prescribed.
- Independent psychiatrist Dr. Schulman also diagnosed mental illness and linked it to coping with vocational rehabilitation; later remanded for reconsideration.
- The ALJ denied compensation in 2007 and the Board affirmed after remands; Muhammad challenged the decision in court.
- The DC court reverses and remands to address legal standards for psych injuries, including Nixon’s quasi-course of employment theory and McCamey/Ramey frameworks.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Board erred by applying a strictly personal reaction test. | Muhammad argues the Board violated McCamey/Ramey by focusing on personal reaction. | DOES contends the Board properly assessed causation. | Error to use strictly personal reaction; remand for proper analysis. |
| Whether Nixon’s quasi-course of employment theory must be considered. | Muhammad argues Nixon supports causal link via rehab. | DOES asserts Nixon’s framework not yet resolved for this record. | Remand to determine Nixon-based causation. |
| Whether McCamey/Ramey frameworks were correctly applied or require clarification. | Muhammad urges application of the correct two-part causation framework. | DOES maintains the current framework is appropriate. | Remand to clarify which framework governs this case. |
| Whether there were verifiable workplace stressors causing the mental injury. | Stressors existed via rehabilitation; must be proven real. | Stressors may be personal reactions, not workplace factors. | Remand to verify factual stressors existed in the workplace. |
| Whether a valid causal chain from the 2002 physical injury to the mental injury is established. | Primary injury may lead to subsequent injury under McCamey. | Need clearer linkage between rehab and mental injury. | Remand to resolve whether an unbroken chain of causation exists. |
Key Cases Cited
- McCamey v. District of Columbia Dep’t of Employment Servs., 947 A.2d 1191 (D.C. 2008) (rejects objective predisposition standard for psychological injuries)
- Ramey v. District of Columbia Dep’t of Employment Servs., 997 A.2d 694 (D.C. 2010) (adopts McCamey framework for mental-mental cases)
- Nixon v. District of Columbia Dep’t of Employment Servs., 954 A.2d 1016 (D.C. 2008) (discusses quasi-course of employment in rehab context)
- Georgetown Univ. v. District of Columbia Dep’t of Employment Servs., 971 A.2d 909 (D.C. 2009) (addresses stressor verification in mental claims)