Appellant worked as a secretary for T. Rowe Price in their sky-scraper. Next door, another skyscraper was being built. This produced an infernal din that bordered on intolerable, despite (or perhaps because) her office was on the top floor. One day, a crane working on that skyscraper accidentally dropped a three ton beam through the roof of her skyscraper. The beam struck five feet from her desk and understandably caused severe damage to the office. Defendant escaped unscathed physically, but came down with post-traumatic stress disorder as a result of the incident.

Procedural History

Workers Compensation Commission denied Appellant recovery on the grounds that her injury was purely mental and therefore not compensable. She appealed to the Circuit Court. The Circuit Court upheld the Commission on the same grounds. The Court of Appeals granted certiorari before the Court of Special Appeals heard the case.


Are purely mental injuries like post-traumatic stress disorder compensable as personal injuries under the Maryland Workers Compensation Act?

Holding and Rational

Yes. Worker’s Compensation covers mental injuries. Reversing existing law and bucking a legal trend, the Court recognized that “mental injuries can be as real as broken bones” and may result in even greater disabilities.

To prevent fraud, the harm must be “real and serious,” and “capable of objective determination.” In the case at bar, appellant’s diagnosis was sufficient evidence to meet the standard.

The Court remanded the case to Circuit Court for a new hearing on the merits. The trial court had not formally found that the mental harm had been the result of a workplace accident.

Belcher v. T. Rowe Price Foundation, Inc. et al., 329 Md. 709 (1993).

Source: Morgan Carlo

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