Doe v. South Carolina Department of Disabilities and Special Needs, 2008 S.C. LEXIS 98 (March 24, 2008)
The Supreme Court reversed the Court of Appeals and remanded the case for the Commission to award benefits to the Appellant because her mental injury arose from unusual or extraordinary conditions of her employment.
Doe was a licensed practical nurse with the South Carolina Department of Disabilities and Special Needs (Department). In 1997, the Department began downsizing and as a result, the patient population in Doe’s unit changed from being a passive group to a mixed group of passive and aggressive patients. The level of noise and violence increased and the number of staff and patient injuries increased. Doe began to suffer from severe depression and was hospitalized. She alleged that her injuries were caused by her job situation.
The Department denied her claim. The single Commissioner and Appellate Panel agreed with the Department and denied Doe’s claim. The Circuit Court reversed the Commission. The Court of Appeals reversed the Circuit Court, finding that substantial evidence existed to support the Commission’s decision that Doe’s injury was not compensable. The Supreme Court reversed the Court of Appeals and found Doe’s injury compensable.
In order for a mental injury to be compensable, it must be incident to or arise from unusual or extraordinary conditions of employment. In this case, the Supreme Court found that there was no substantial evidence to support the Court of Appeals decision that the conditions of Doe’s employment at the time of her injury were not unusual or extraordinary. The Supreme Court agreed with the Circuit Court’s analysis that the mix of passive and aggressive patients was an extraordinary and unusual condition of Doe’s employment and caused her stress-related mental injury. The case was remanded to the Commission to award benefits to Doe based on her disability arising from her mental injury.
