In Lawson v. Costar Group, Inc. discusses below, the Tennessee Workers’ Compensation Appeals Board reiterated that ordinary job stress, such as fear of losing one’s job, is not a compensable mental injury in Tennessee Workers’ Compensation claims.
Julie Lawson, an employee of Costar Group, Inc., filed a workers’ compensation claim after alleging that she suffered a work-related mental injury due to actions by certain supervisors in February 2023. Lawson, who had a pre-existing diagnosis of PTSD, claimed that two specific work events exacerbated her condition.
First, during a virtual meeting on February 28, a colleague casually used the word “kidnapped,” which Lawson said triggered her PTSD. Although Lawson acknowledged the word was used in passing, she testified that it caused her shock and anxiety, prompting her to take a walk and a drive during her lunch break to recover.
Later that day, Lawson attended her annual performance review, which, although not conducted by her direct supervisor, was prepared by him. Lawson had previously accused this supervisor of sexual harassment, and she believed that the male supervisors who conducted the review were aware of the ongoing investigation into her allegations.
She felt that their dismissive behavior and the timing of the performance review were designed to cause her harm. Lawson claimed that the review was out of the ordinary and caused more stress than what a reasonable person in her position would have expected.
After these events, Lawson sought treatment from her psychiatrist, Dr. Susanna Quasem, who diagnosed her with “complex PTSD” and linked her condition’s aggravation to the work-related events of February 28. Lawson argued that these events were extraordinary and unusual stressors that justified her workers’ compensation claim.
In response, Costar Group filed a motion for summary judgment, claiming that the events Lawson described were not extraordinary compared to typical workplace stress and that her evidence was insufficient to support a claim of mental injury. The employer also argued that mental injuries arising from the loss of employment or employment opportunities were not covered under Tennessee’s Workers’ Compensation Law.
The trial court granted summary judgment in favor of the employer, dismissing Lawson’s case. The court reasoned that the stress Lawson experienced during the performance review was not unusual for employees in similar situations and concluded that her mental injury did not result from a sudden or unusual stimulus.
It also noted that Lawson’s alleged harm was related to the potential loss of employment, which Tennessee law excludes from mental injury claims.
Lawson appealed, arguing that the trial court erred in granting summary judgment. She contended that the employer had not demonstrated that her evidence was insufficient and that there were disputed material facts, particularly regarding whether the events of February 28 constituted a sudden or unusual stimulus.
The Workers’ Compensation Appeals Board reversed the trial court’s decision, finding that the trial court had not considered the evidence in Lawson’s favor and had applied an incorrect legal standard. The Board concluded that whether the performance review and its timing were extraordinary was a question of fact and that summary judgment was not appropriate. The case was remanded for further proceedings to determine whether Lawson’s claim could be substantiated.
In conclusion, the Appeals Board found that the trial court had made errors in its judgment, and the case was sent back for further investigation.
If You’ve Been Injured at Work, Contact a Knoxville Workers’ Compensation Lawyer
If you have been injured at work and are facing challenges with medical treatment or workers’ compensation benefits, contact a Knoxville workers’ compensation lawyer to help you understand your rights and navigate the legal process. The Lawyers of Brown & Roberto can help you secure the compensation you deserve.