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 financial institutions examiner supervisor for the New Mexico State Financial Institutions Division, experienced significant work-related stress due to staff reductions and increased workload starting in 1987. This led to anxiety, depression, and a neurochemical imbalance diagnosed by a psychiatrist. The worker sought psychiatric treatment, was hospitalized, and later filed for workers' compensation benefits, claiming temporary total disability and reimbursement for medical expenses (paras 2-4).
Procedural History
- Workers' Compensation Administration: Denied the worker's claim for benefits, finding no compensable injury or disability under the Workers' Compensation Act.
Parties' Submissions
- Appellant (Worker): Argued that his stress-induced neurochemical depression constituted a "physical impairment" under the Workers' Compensation Act and that he was entitled to temporary total disability benefits and medical expenses (paras 5-7, 18).
- Respondent (Employer): Contended that the worker's condition was a "mental impairment" not covered under the Act, as it did not result from a psychologically traumatic event or physical injury. The employer also argued that medical benefits were contingent on a compensable injury (paras 7, 19).
Legal Issues
- Whether the worker's stress-induced neurochemical depression qualifies as a "physical impairment" under the Workers' Compensation Act (para 7).
- Whether the worker is entitled to medical benefits despite not having a compensable impairment under the Act (para 18).
- Whether the worker is entitled to temporary total disability benefits (para 17).
Disposition
- The court affirmed the denial of workers' compensation benefits, finding that the worker's condition was a "mental impairment" not compensable under the Act (para 26).
Reasons
Per Donnelly J. (Hartz J. concurring):
The court held that the worker's neurochemical depression, though biochemically diagnosable, was a "mental impairment" under the Workers' Compensation Act and not a "physical impairment" as argued by the worker. The Act limits compensable mental impairments to those caused by a psychologically traumatic event outside the worker's usual experience or resulting from a physical impairment. The worker's condition did not meet these criteria (paras 7-13).
The court also determined that medical benefits under Section 52-1-49 are contingent on a compensable injury as defined by the Act. Since the worker's condition was not compensable, he was not entitled to medical benefits. The court emphasized that the Workers' Compensation Act is fundamentally a disability compensation scheme, and medical benefits cannot be divorced from the requirement of a compensable injury (paras 18-23).
Finally, the court denied the worker's request for attorney's fees, as such fees are only awarded when compensation or medical benefits are granted (para 25).
Chavez J., dissenting:
Chavez J. dissented, arguing that the legislative amendments to the Workers' Compensation Act were intended to limit eligibility for income benefits, not to exclude gradual, stress-induced injuries from the Act entirely. He contended that the worker's condition met the threshold for an accidental injury arising out of and in the course of employment, entitling him to medical benefits. Chavez J. criticized the majority for interpreting the Act too broadly and departing from its plain language (paras 28-31).