Candelaria v. General Electric Co.
105 N.M. 167, 730 P.2d 470 (1986)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A psychological disability caused by emotional stress arising out of and in the course of employment, even without an accompanying physical injury, is compensable under the New Mexico Workmen’s Compensation Act if it is causally related to actual job duties.
Facts:
- Robert Lee Candelaria, a 43-year-old high school graduate with prior management experience, began working for General Electric (G.E.) as a janitor, hoping to advance to a plating job.
- Candelaria eventually became a “process varied” operator, preparing jet engine parts for plating, a role he initially performed without emotional difficulties while on the night shift under Supervisor Gianini.
- Candelaria's problems began when he was transferred to the day shift and placed under Supervisor Jewett, who soon assigned him additional duties from a different job classification without providing help.
- Candelaria complained to Jewett, the union, plant officials, and the Labor Board about his increased workload and the stress it caused, but no effective action was taken, and a promised new worker was not hired.
- On or about May 13, 1981, after an unsatisfying meeting with the plant manager and while receiving more orders from Jewett, Candelaria started shaking, felt like killing Jewett, began crying, sweating, and experienced chest pains, leading to his first hospitalization.
- Candelaria was repeatedly hospitalized for psychological problems after returning to work and being placed under Jewett again, each time suffering similar symptoms when asked to perform the same demanding tasks.
- After his fourth hospitalization, Candelaria requested a transfer and was placed under a different supervisor, but a fifth hospitalization occurred in January 1983 after he saw Jewett at a deposition and experienced chest pains and hyperventilation.
- Psychiatrists Drs. Fredman and Sacks diagnosed Candelaria with severe anxiety and depression disorders, concluding that the events and stress at G.E., particularly the conflict with Jewett, triggered his disability, despite acknowledging potential predispositions.
Procedural Posture:
- Robert Lee Candelaria filed a claim against General Electric Co. in the New Mexico district court.
- The district court found in favor of Candelaria, ruling him temporarily totally disabled for a period and permanently partially disabled thereafter, and also found that accidental injuries occurred on May 13, 1981, and before each subsequent hospitalization.
- General Electric Co. moved for a new trial and for post-judgment relief after discovering Candelaria had been working at the time of trial.
- The district court denied the motion for post-judgment relief, finding that the new employment did not alter the medical opinions regarding Candelaria's disability.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a psychological disability caused by emotional stress, without accompanying physical injury, constitute a compensable accidental injury under the New Mexico Workmen’s Compensation Act when the stress arises out of and is causally related to actual job duties?
Opinions:
Majority - Alarid, Judge
Yes, a psychological disability caused by emotional stress, without accompanying physical injury, is a compensable accidental injury under the New Mexico Workmen’s Compensation Act when the stress arises out of and is causally related to actual job duties. The court held that the Act's language, which makes no distinction between physical and mental injuries for an 'accidental injury,' allows for compensation for psychological disabilities resulting from work-related stress. Previous New Mexico cases have established that psychological disability is a 'disability' and that physical disabilities resulting from work-related emotional stress are compensable, logically extending this to emotional stress causing psychological disability. The court rejected the 'unusual or extraordinary condition' standard from other jurisdictions (like School District #1 v. Department of Industry, Labor & Human Relations) and the 'clear and convincing evidence' standard for predisposed workers (Townsend v. Maine Bureau of Public Safety), finding no basis for such differentiation in the Act. The court clarified that the stress must stem from 'actual job conditions' rather than 'imagined stress,' and found substantial evidence that Candelaria's stress was actual and causally related to his work duties with Jewett, as supported by expert medical testimony.
Analysis:
This case significantly expanded the scope of worker's compensation in New Mexico by explicitly recognizing psychological injuries caused by work-related emotional stress as compensable, even without physical trauma. It establishes New Mexico as a progressive jurisdiction in this area, rejecting stricter standards adopted by other states that require unusual stress or higher burdens of proof for mental injuries. The ruling clarifies that the Act's purpose is to cover disabilities flowing from employment conditions, regardless of whether they are labeled organic or psychic. Future cases will likely build on the 'actual stress' requirement, further defining what constitutes real working conditions that cause compensable psychological injury.
