AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The Worker, employed as a swimming pool manager for the City of Santa Fe, was tasked with cleaning and maintenance duties, including addressing a severe pigeon infestation at an outdoor pool. In March 2003, the Worker cleaned approximately 160 pounds of pigeon feces and carcasses from the roof, experiencing headaches and nausea afterward. The City later hired a company to remove 1.5 tons of pigeon matter. On June 5, 2003, the Worker developed symptoms such as photophobia, nausea, disturbing dreams, and body tremors, which were later attributed to psychological conditions (paras 2-3).

Procedural History

• Workers' Compensation Administration: The Workers' Compensation Judge (WCJ) denied the Worker's claim for compensation, finding that the Worker did not suffer a "psychologically traumatic event" as required under NMSA 1978, § 52-1-24(B) (paras 5-6).

Parties' Submissions

• Appellant (Worker): Argued that the WCJ's finding that he did not suffer a psychologically traumatic event was unsupported by substantial evidence, that the WCJ misinterpreted the law by requiring a "catastrophic" event, and that such a requirement violated the equal protection clause of the New Mexico Constitution (para 7).
• Appellee (City of Santa Fe): Defended the WCJ's decision, asserting that the Worker's experiences did not meet the statutory definition of a psychologically traumatic event and that the statute was constitutional.

Legal Issues

• Did the Worker suffer a "psychologically traumatic event" under NMSA 1978, § 52-1-24(B)?
• Did the WCJ misinterpret the law by requiring a "catastrophic" event to satisfy the statutory definition?
• Does the statutory requirement of a psychologically traumatic event violate the equal protection clause of the New Mexico Constitution?

Disposition

• The Court of Appeals affirmed the WCJ's decision, denying the Worker's claim for compensation (para 34).

Reasons

Per Pickard J. (Bustamante CJ. and Robinson J. concurring):

The Court held that the Worker did not suffer a "psychologically traumatic event" as required under NMSA 1978, § 52-1-24(B). The statute requires a specific, identifiable, and significant traumatic event that is generally outside a worker's usual experience and would evoke significant distress in similar workers. The Worker's experiences cleaning pigeon matter were ongoing and stress-inducing but did not constitute a specific, identifiable traumatic event (paras 10-15, 20-25).

The Court rejected the Worker's argument that the WCJ improperly required a "catastrophic" event, clarifying that prior case law, including Jensen v. New Mexico State Police, established that the statute limits compensable claims to significant traumatic events. The Court found that the WCJ's decision was based on the absence of a specific traumatic event, not on the severity of the events (paras 16-20).

The Court also dismissed the Worker's equal protection challenge, noting that the New Mexico Supreme Court in Breen v. Carlsbad Mun. Schs. upheld the proof requirements of § 52-1-24(B) as valid and permissible. The Court found no constitutional violation in requiring a psychologically traumatic event for mental disability claims under the Workers' Compensation Act (paras 28-33).