AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Worker was involved in an accident during the course of his employment, which involved a fire. This incident led to the Worker being diagnosed with Post-Traumatic Stress Disorder (PTSD) by both his therapist and an independent psychologist, with the diagnosis based on the Diagnostic and Statistical Manual of Mental Disorders (DSM) criteria. Despite this, the Workers' Compensation Judge (WCJ) found that the accident would not have evoked significant symptoms of distress in other workers similarly situated and denied benefits.

Procedural History

• Appeal from the Workers’ Compensation Administration, Shannon S. Riley, Workers Compensation Judge: Denied benefits to the Worker.

Parties' Submissions

• Worker-Appellant: Argued that he is entitled to benefits for a primary mental impairment resulting from an accident at work, which was diagnosed as PTSD by medical professionals.
• Employer/Insurer-Appellee (City of Albuquerque): Supported the WCJ's rationale that the accident would not have evoked significant symptoms of distress in other workers similarly situated and thus opposed the Worker's claim for benefits.

Legal Issues

• Whether the Worker is entitled to benefits for a primary mental impairment under NMSA 1978, § 52-1-24(B) (1991), given the diagnosis of PTSD following an accident at work.

Disposition

• The Court of Appeals reversed the decision of the Workers’ Compensation Judge, granting benefits to the Worker.

Reasons

• Per Roderick T. Kennedy, J. (Michael D. Bustamante, J., Timothy L. Garcia, J., concurring): The Court found that the Worker's accident, involving a fire, and subsequent diagnosis of PTSD by both his therapist and an independent psychologist based on the DSM criteria, satisfied the statutory definition of a "primary mental impairment." The Court rejected the WCJ's finding that the accident would not have evoked significant symptoms of distress in other workers similarly situated, noting that the legislative intent behind Section 52-1-24(B) is to cover sudden, emotion-provoking events of a catastrophic nature that could lead to PTSD, as opposed to gradual, stress-producing causes. Given the uncontradicted medical evidence that the Worker met the DSM's definition of PTSD, the Court concluded that the event was sufficiently traumatic to warrant benefits under the statute.