holding that benefits were unavailable to claimant where the decedent’s “self-imposed expectations and his perception of success,” rather than work conditions, caused his suicide
How later courts described this case
- holding that benefits were unavailable to claimant where the decedent’s “self-imposed expectations and his perception of success,” rather than work conditions, caused his suicide
- adopting “abnormal working conditions” requirement in mental/mental context
- discussing the mental/mental standard of proof
- decided together with Martin v. Ketchum
Written by the judges who cited it.
Distinguished
Distinguished by Davis v. Workmen's Compensation Appeal Board, 561 Pa. 462 (2000)
In this case, Davis asserts that Martin is inapplicable because he suffered not only from a psychic reaction to his working conditions, but also a physical reaction.
Distinguished by Vactor v. Workers' Compensation Appeal Board (Glenn's Dairy, Inc.), 1997 Pa. Commw. LEXIS 371 (1997)
But, in a case where a physical stimulus causes a mental injury, the heightened burden of proof explained in Martin is inapplicable.
Distinguished by Halvorsen v. Workmen's Compensation Appeal Board, 159 Pa. Commw. 35 (1993)
As a preliminary matter, we note that the burden of proof for psychiatric injuries articulated in Martin v. Ketchum, Inc., 523 Pa. 509, 568 A.2d 159 (1990), is inapplicable to this case.
The opinion
concurring and dissenting.
I dissent. I believe the record amply demonstrates that Martin’s self-destruction was caused by his employment. He was, as the Majority suggests, a strong-willed, successful individual and when his strong will met resistance, on the job, in Michigan, he began to experience mental reservations concerning his work abilities. His subsequent reassignment to a less prestigious project for the Salvation Army campaign intensified his stress, on the job, and eventually led to his suicide. Clearly, the conditions of his employment brought about his death. I believe the referee and the Board correctly decided this claim and I would reverse the Commonwealth Court.
With respect to the Benesky appeal, I concur in the result reached by the Majority.
*523 LARSEN, Justice,