Wood v. Laidlaw Transit, Inc., 77 N.Y.2d 56 (1990)
An employee who experiences psychological trauma resulting in mental injury from witnessing a horrific event during the course of their employment, in which their job places them as an active participant, can be eligible for workers’ compensation benefits.
Summary
Rose Wood, a school bus driver, sought workers’ compensation after developing post-traumatic stress disorder (PTSD) from witnessing a fatal car accident involving high school students she knew while on her route. The New York Court of Appeals held that Wood, by virtue of her employment and the responsibilities it entailed, was an active participant in the event and therefore, suffered an accidental injury within the meaning of the Workers’ Compensation Law. The court emphasized that her role was more than that of a mere bystander and that her feeling of responsibility contributed to her psychological injury.
Facts
Rose Wood worked as a school bus driver for Laidlaw Transit, Inc. On April 29, 1986, while driving a bus full of kindergarten children, Wood came upon a car accident where two high school students she knew had died. Wood was the first to arrive. She saw the mangled body of one of the victims. Concerned for the safety of the children on the bus and feeling a duty to remain at the scene until help arrived, Wood stayed on the bus with the children. Within weeks, Wood developed psychological symptoms, including insomnia, nightmares, anorexia, depression, and chest pains. She was later diagnosed with PTSD, making it impossible for her to continue working as a school bus driver.
Procedural History
The Workers’ Compensation Law Judge initially rejected Wood’s claim. The Workers’ Compensation Board reversed, finding her injury compensable. The Appellate Division reversed the Board’s decision and dismissed the claim, holding that no accident had occurred within the meaning of the Workers’ Compensation Law. The New York Court of Appeals then reversed the Appellate Division’s order and reinstated the Board’s determination.
Issue(s)
Whether a school bus driver who suffers psychological trauma and mental injury from witnessing a fatal accident during her work is considered to have suffered an “accidental injury” arising out of and in the course of employment, thus entitling her to workers’ compensation benefits.
Holding
Yes, because Rose Wood was by virtue of her employment an active participant and more than a third party merely witnessing another’s injury; therefore, she suffered an “accidental injury” and is entitled to workers’ compensation benefits.
Court’s Reasoning
The court reasoned that psychological injury precipitated by psychic trauma can be an accidental injury compensable to the same extent as a physical injury, citing Matter of Wolfe v Sibley, Lindsay & Curr Co. (36 NY2d 505). The court distinguished this case from Matter of Everett v A. S. Steel Rule Die Corp. (66 NY2d 683), where the claimant merely observed a co-worker’s bandaged hand. The court emphasized that Wood’s job responsibilities involved her in a unique way, differentiating her from other passersby. Her feeling of responsibility for the children on the bus and her inability to assist the accident victims contributed to her psychological injuries. The court stated, “Rather, ‘active participants’ are simply one category of claimants who might recover workers’ compensation for injuries that result from witnessing events that befall someone else.” The court explicitly did not decide whether workers’ compensation is available to persons in other circumstances who suffer mental harm from witnessing an injury to someone else.