Matter of Wilson v. Tippetts-Abbott-McCarthy-Stratton, 22 N.Y.2d 987 (1968)
A work-related injury is not compensable under worker’s compensation if it results from stress or exertion that is no greater than the ordinary wear and tear of life.
Summary
This case concerns a claim for worker’s compensation benefits following an employee’s collapse after a prolonged argument at work. The New York Court of Appeals reversed the Appellate Division’s order and dismissed the claim, holding that the emotional strain experienced by the employee did not exceed the ordinary stresses of daily life and therefore was not compensable. The court emphasized that the altercation did not constitute an unusual or excessive level of stress compared to what individuals typically encounter.
Facts
The decedent, an employee, was involved in a prolonged argument at work on July 24, 1964. Following the argument, the employee collapsed. The Workmen’s Compensation Board initially determined that the argument involved greater stress and exertion than the ordinary wear and tear of life, leading to the collapse.
Procedural History
The Workmen’s Compensation Board initially ruled in favor of the claimant. The Appellate Division affirmed the Board’s decision. The New York Court of Appeals then reviewed the Appellate Division’s order.
Issue(s)
Whether the emotional strain and exertion experienced by the employee during the work-related argument constituted stresses greater than the ordinary wear and tear of life, thus qualifying the subsequent collapse as a compensable injury under worker’s compensation law.
Holding
No, because the altercation did not involve stresses or strains greater than ordinary wear and tear of life.
Court’s Reasoning
The Court of Appeals determined that the Workmen’s Compensation Board’s finding was incorrect as a matter of law. The court relied on precedent, citing several cases where similar claims were denied because the stress experienced was not beyond what is considered the “ordinary wear and tear of life.” The court provided no specific details of the argument, but its brevity suggests the facts were not extreme. By referencing previous decisions, the court emphasized the necessity of a high threshold for establishing that work-related stress exceeded normal life stresses. The court stated, “the prolonged argument and emotional strain participated in by the decedent prior to his collapse on July 24, 1964 involved greater stress and exertion than the ordinary wear and tear of life.” On this record such finding is incorrect, as a matter of law.” This case reinforces the principle that not every adverse event at work leading to injury is compensable; the stress must be significantly beyond the normal experiences of daily living. Judges Burke and Bergan dissented, favoring affirmance based on the Appellate Division’s prevailing opinion, while Judge Gibson took no part in the decision.