Social Worker’s Evidence Connects Details of Client’s Murdering Someone to Job-related PTSD

Minneapolis, MN (WorkersCompensation.com) -- What does it take for a worker in Minnesota to establish that she experienced PTSD because of her job?

That was the question the state's top court faced in Tea v. Ramsey County, No. A23-1207 (Minn. 04/17/24), in which a social worker alleged that she developed PTSD after hearing the grisly details of how one of her clients murdered his girlfriend.

A social worker for a county reported a post-traumatic stress injury during her employment related to her exposure to the details of a murder that one of her clients committed.

The county initially provided workers' compensation benefits to the social worker but discontinued those benefits after a licensed psychiatrist concluded that the social worker did not have PTSD. According to this psychiatrist, the social worker's complaints were consistent with her history of anxiety, depression, and ADHD and were likely the result of "burn out."

The social worker filed an objection, and the compensation judge determined that she had compensable PTSD, based on the reports of three doctors who opined that the social worker experienced PTSD and Major Depressive Disorder.

Workers' Comp 101: On appeal, the issue of the social worker's Major Depressive Disorder did not go forward because in Minnesota, major depression injuries are not compensable by themselves and must be pleaded as a consequential injury to PTSD. See Chrz v. Mower County, 986 N.W. 2d 481 (Minn. 2023).

The Workers' Compensation Court of Appeals affirmed, prompting the county to appeal to the Minnesota Supreme Court, arguing that the social worker did not meet the diagnostic criteria listed in the Diagnostic and Statistical Manual of Mental Disorders.

In Minnesota, a compensation judge can award compensation for PTSD only if the employee proves that: 1) a psychiatrist or psychologist has diagnosed the employee with PTSD; and 2) the professional based the employee's diagnosis on the latest version of the DSM.

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In upholding the WCCA's affirmance of the compensation judge's finding, the Minnesota Supreme Court found that the WCCA faced a choice of choosing between conflicting medical conclusions and was within its authority to side with the doctors that diagnosed the social worker with PTSD.

"The compensation judge was presented with competing expert reports, those reports had adequate foundation, and the judge made a choice based on all the evidence before him," the court wrote. "Because this choice does not clearly require a contrary conclusion, the WCCA's affirmance of the compensation judge's finding is not manifestly contrary to the evidence."

Thus, the court affirmed the WCCA's upholding of the compensation judge's decision to award compensation to social worker for her job-related PTSD.

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