Scott B. Schuette v. City of Hutchinson. MN workers comp, PTSD
Scott B. Schuette was a full-time police officer with the City of Hutchinson. On June 23, 2005, he responded to an accident at the high school. A girl had fallen out of a pickup truck, and officer Schuette realized that he knew the victim and her family. He administered CPR and drove the victim to the hopsital. At the hopsital, he started to feel sick, had dry heaves, was in a daze, and reported that "nothing was registering."
He later began to experience mental health problems such as anxiety, panic attacks, nightmares, flashbacks, hypervigilance, and insomnia. He had a mental health evaluation in 2008, and was diagnosed with post-traumatic stress disorder (PTSD). He later suffered a shoulder and back injury as a result of a fall during a nightmare. In 2009, he resigned from his position and filed a workers' compensation claim.
The Workers Compensation judge denied the claim because the PTSD is a mental disability, which is not compensible under Minnesota workers' comp. Under Lockwood v. Independent School 2 District No. 877, 312 N.W.2d 924 (Minn. 1981), a mental injury is compensible only if it includes a physical component. The Workers Compensation Court of Appeals affirmed, and Schuette appealed to the Minnesota Supreme Court. He argued that because of the shoulder injury, he suffered a compensable personal injury. He also argued that Lockwood should be overruled.
The Supreme Court first examined the medical evidence and concluded that the finding of no compensible personal injury was supported by the evidence, and affirmed.
The Court also declined to overrule Lockwood. Schuette argued that the distinction between physical and mental injuries was unconstitutional. But the Court held that there was a rational basis for distinguishing between these types of injuries.
For these reasons, the Supreme Court affirmed the denial of Schuette's claim.
No. A13-0840 (Minn. Mar. 5, 2014).
Please see the original opinion for the court's exact language.
Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).
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