California’s 6th District Court of Appeal ruled in the case involving Aaron Matea that the circumstances of his September 2001 injury met the legal requirements for paying psychiatric benefits for a worker employed less than six months. The appellate court overturned a decision by the state Workers’ Compensation Appeals Board (WCAB).
State law requires employees show their underlying psychiatric injury was caused by a “sudden and extraordinary employment condition,” the ruling said. Case law interpreting the provision has suggested gas main explosions or incidents of workplace violence would qualify under California statutes.
“Gas main explosions and workplace violence are certainly uncommon and usually totally unexpected events; thus, they may be sudden and extraordinary employment conditions,” the court wrote in the Matea ruling. “However, we believe that there may also be other “sudden and extraordinary” occurrences or events within the contemplation of section 3208.3, subdivision (d), that would naturally be expected to cause psychic disturbances even in diligent and honest employees.”
According to court records, Matea hurt his left foot and ankle in the lumber accident and reported that he also suffered from depression and related fear he would be reinjured. A workers compensation judge found Matea was 100% permanently disabled and entitled to $314.40 per week for life, but the WCAB disagreed.
TheSan Jose-based appeals court threw out WCAB decision and sent it back, ordering the board to issue a new order.The ruling in Aaron B. Matea vs. Workers’ Compensation Appeals Board is here .