A psychiatric nurse heard a speech at a work-related presentation that brought back painful memories for him. He said the event triggered post-traumatic stress disorder and depression, and he filed for workers’ comp which his employer initially denied. He filed a lawsuit in McMinn County, TN against his employer but when it was also denied by the trial court the claimant appealed.

William Ireton was attending a training seminar at an annual conference put on by his employer, Horizon Mental Health Management LLC. He worked in the Woods Memorial Hospital psychiatric unit and his responsibilities included talking to patients and their families about their progress and meeting with their doctors. Upon his hire he did not receive clinical training but began attending the company’s annual conferences which have educational training sessions. During the trauma-sensitive care training session at the 2012 annual conference, the senior vice president of clinical practice for the company, Barbara Lang, told those in attendance “I want you to put yourself in your patient’s shoes and imagine how it would feel when you’re asked, ‘Have you ever been physically, emotionally, or sexually abused?’”

Ireton had been a victim of abuse himself and this statement shook him, he had horrible flashbacks and stayed in a dazed and numb state for several days. He had never had severe flashbacks about the incident before. He left work about a month after the conference and was seeing a doctor for depression, he found it too difficult to return to any job as he was unable to concentrate.

He argued that the suggestion that Ms. Lang made was not a part of his duties, and he had never been trained to do that or asked to do that during his employment. He said he had been taught as a crisis stability nurse, not to put yourself in the patient’s shoes. He said it was rare for him to talk to patients about their history and if they answered that they were abused, he did not go further into detailed questioning. His treating doctor, Dr. LeBuffe, said that the statements may have triggered underlying psychological symptoms but the claimant had not had such intense symptoms before where he was unable to work. Dr. LeBuffe also testified that it was not an uncommon part of a mental health professional’s job to take the history of or talk to a patient who has been abused.

The trial court determined that his injuries could not be compensable because they did not come about through his employment with Horizon, or they did not result from a stressful event that was unusual compared with the typical stress experienced at work. The statement Ms. Lang made was similar to statements she had made in every conference for years, and it was not an unusual statement or circumstance that deviated from the norm. Her statement was not directed specifically at the claimant or about any of his specific patients; it was a statement to all the employees in general. Lang testified that she expects nurses in crisis units to develop some kind of understanding or aligning relationship with patients to better help them and find out what treatment they need.

The case made its way to the Tennessee Supreme Court’s Special Workers’ Compensation Appeals Panel. They upheld the ruling, agreeing that her statement was not abnormal or any more stressful than what someone might experience working in such a crisis unit.