Des Moines, IA (WorkersCompensation.com) – A worker’s termination led to tragedy when, shortly after receiving the news, he took his own life.
However, whether that created a workers’ compensation claim for his surviving wife was a question the Iowa Court of Appeals recently had to decide.
A worker for a tire manufacturer engaged in acts of insubordination and was caught lying about those acts. Because of this, he was suspended for a “cooling off period,” during which an investigation was conducted.
Following the investigation, the manufacturer terminated the worker. After learning the news, the worker called his wife to let her know. The wife arrived home before the worker, and when the worker arrived home, he went to the garage and did not enter the home. When the wife went to the garage to check on the worker, he had locked himself inside and left his vehicle running. The wife convinced him to come out, but he left the home shortly afterward.
Later, the worker was found dead at a nearby bridge, and law enforcement determined that he took his life by hanging. The worker had a history of substance abuse but had been sober for several years. He had also been diagnosed with major depressive disorder and anxiety disorder and reported hating people, but not anyone from his job.
The worker was recommended to attend psychotherapy and did, but he declined a referral for psychiatric treatment. He underwent an initial social history assessment, at which he presented issues with anger and rage. He was additionally diagnosed with intermittent explosive disorder. The worker was discharged from treatment due to scheduling issues with his provider, but the counselor recommended he continue therapy. However, he did not seek further treatment.
The wife sought workers’ compensation death benefits. The matter proceeded to an arbitration hearing. A deputy commissioner concluded that the worker’s mental conditions were “rooted in personal issues” outside of his employment, the worker’s fear of termination and psychological pain were not injuries arising in the course of his employment, and his death was not causally related to his termination.
Following the denial of benefits, the wife appealed to a commissioner, who upheld the deputy’s decision. Following that, she appealed to court. The court agreed that the evidence did not show any mental injury on the worker’s part that was related to job.
The wife appealed to the next level in court.
In Iowa, legal causation for a mental injury is established when the mental injury is caused by workplace stress of greater magnitude than the day-to-day stresses experienced by other workers employed in the same or similar jobs.
Was the workplace stress the legal cause of the worker’s mental injury leading to his suicide?
A. Yes. Legal causation for the worker’s mental injury was established as a result of a traumatic mental injury triggered by the termination and the events leading up to the termination
B. No. The evidence didn’t show that the worker was subjected to unusual stress on the job.
If you chose B, you agreed with the court in Jackson v. Bridgestone Americas Tire Operations LLC, No. 21-0017 (Iowa Ct. App. 12/15/21), which affirmed the lower court’s ruling in the manufacturer’s favor, explaining that, even assuming a mental injury occurred as a result of termination or leading up to it, the wife presented no evidence that the resulting stress was of greater magnitude than the mental stress experienced by other workers in the same or similar jobs who were terminated for insubordination. As a result, the court determined that the worker did not experience anything that connected his alleged injury to his employment, particularly because the wife did not present a comparison of the stress endured by similarly situated employees to show that the worker’s stress was unsual.
Editor’s note: This feature does not provide legal advice.