St. Louis, MO (WorkersCompensation.com) – Some days, the old adage about “work” being a four-letter word rings true, but how much stress on the job does it take to enter the realm of workers’ compensation?
For the maintenance engineer seeking benefits in Shipley v. State of Missouri Office of Administration, No. SD36643 (Mo. Ct. App. 10/27/20), not showing “medical difficulties beyond a few generalities” sunk his claims that “extraordinary workplace stress” entitled him to benefits.
History of Conflict
The engineer worked at a power plant and had a history of conflicts with subordinates, peers, superiors, and vendors. This culminated in an incident where the engineer refused to turn off a boiler scheduled for repairs, got into shouting matches with his supervisor and subordinates, and left in his truck.
He returned to work briefly the next day but ended up being taken by ambulance to an emergency room and then to another hospital for psychiatric care. Following this incident, the engineer resigned and filed a claim for compensation based on workplace stress.
Following a hearing on the engineer’s case, an administrative law judge determined that the engineer did not prove that the events he described objectively rose to the level of “extraordinary and unusual stress,” so he appealed to the state’s workers’ compensation commission.
A majority of the commission affirmed the ALJ’s ruling, prompting the engineer to take his case to state court.
Under Missouri law, employees seeking benefits for mental injuries must establish that they arose out of and in the course of employment by showing that, objectively, they experienced extraordinary and unusual stress on the job.
The court found no evidence of such stress in the engineer’s evidence. Instead, according to the court, what the engineer experienced wasn’t much different from what “other power plant managers or other similarly situated employees” in their jobs.
In particular, the court explained that while the engineer’s arguments were “prolix,” they didn’t provide information that compared his level of stress to that faced by other employees in the same profession. While the engineer represented that he had a depressive disorder, his case in court didn’t provide enough information to let the court conclude that the mental injury arose out of and in the course of his employment.
As a result, the court affirmed the ALJ’s and commission’s decisions against the engineer.