Matter of Gordon v. New York Life Insurance Company, 32 N.Y.2d 718 (1973)

An injury precipitated by work-related emotional stress can be a compensable industrial accident under workers’ compensation law, especially when interacting with a pre-existing physical condition.

Summary

This case addresses whether an employee’s disability, caused by emotional stress at work exacerbating a pre-existing diabetic condition, qualifies as a compensable industrial accident. The Workmen’s Compensation Board found that the claimant’s prolonged anxiety and specific emotional episodes at work caused blood vessel breakage and hemorrhages, leading to disability. The Court of Appeals reversed the Appellate Division’s decision and reinstated the Board’s award, holding that the evidence supported the finding that work-related emotional stress contributed to the claimant’s injuries, thus constituting a compensable industrial accident.

Facts

The claimant experienced a prolonged state of anxiety and tension at work. Two specific emotional episodes occurred on April 8, 1968, and December 4, 1968. These episodes, reacting upon the claimant’s underlying diabetic condition, led to the breakage of blood vessels and hemorrhages. Medical diagnoses supported the causal link between the emotional stress and the resulting physical injuries. The treating ophthalmologist testified that either of the emotional episodes was sufficient to cause the hemorrhages and the resultant disability.

Procedural History

The Workmen’s Compensation Board initially found that the claimant’s injuries constituted a compensable industrial accident. The Appellate Division reversed this decision. The Court of Appeals then reversed the Appellate Division’s order and reinstated the original award by the Workmen’s Compensation Board.

Issue(s)

Whether a disability caused by work-related emotional stress that exacerbates a pre-existing physical condition (diabetes) constitutes a compensable industrial accident under workers’ compensation law.

Holding

Yes, because the record supported the Board’s finding that a prolonged state of anxiety and tension and specific emotional episodes at work, reacting upon claimant’s underlying diabetic condition, caused the accidental injuries and disability claimed. The medical diagnoses causally related the emotional stress and the claimant’s resultant condition.

Court’s Reasoning

The Court reasoned that substantial evidence supported the Workmen’s Compensation Board’s finding that the claimant’s emotional condition, triggered by work-related events, led to physical injuries. The Court cited previous cases, including Matter of Sawatzki v. Friedman and Matter of Klimas v. Trans Caribbean Airways, to support the principle that injuries resulting from excessive emotional stress at work are compensable. The Court emphasized that the treating ophthalmologist’s testimony established causation without relying on the specific details of a “heated discussion,” indicating that the emotional episodes themselves were sufficient to cause the disability. The court stated, “The record affords substantial evidentiary support for the board’s finding of a prolonged state of anxiety and tension and an overwrought emotional condition which, with the precipitant effects of the emotional episodes of April 8, 1968 anfi December 4, 1968, reacting upon claimant’s underlying diabetic condition, caused the accidental injuries and disability claimed.” Judge Jasen concurred on constraint of Matter of Klimas v. Trans Carribean Airways. Judge Scileppi dissented and voted to affirm the Appellate Division’s decision.