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

A paramedic employed by the City of Albuquerque claimed to suffer from Post-Traumatic Stress Disorder (PTSD) due to exposure to four specific traumatic events during his employment. These events included responding to incidents involving the death of children and other distressing situations. The paramedic sought workers' compensation benefits, asserting that these events were outside the usual experience of his job (paras 4-9).

Procedural History

• Workers' Compensation Administration, November 15, 1994: The Workers' Compensation Judge granted summary judgment in favor of the City of Albuquerque, holding that the paramedic's claim was precluded under Section 52-1-24(B) of the Workers' Compensation Act because his job inherently involved exposure to traumatic events (paras 1, 11).

Parties' Submissions

• Appellant (Paramedic): Argued that the four traumatic events were qualitatively different from his usual work experiences and met the statutory requirements for a compensable primary mental impairment. He contended that the events were psychologically traumatic and outside the usual experience of workers in similar roles (paras 10, 16-17, 27).
• Appellee (City of Albuquerque): Asserted that the paramedic's PTSD resulted from ongoing stress inherent in his job and not from specific traumatic events. The City argued that the events described were not outside the usual experience of paramedics and that the claim was based on progressive stress, which is not compensable under the Act (paras 10, 27).

Legal Issues

• Whether Section 52-1-24(B) of the Workers' Compensation Act excludes workers in occupations involving routine exposure to traumatic events from claiming compensation for primary mental impairment.
• Whether the four events described by the paramedic constituted "psychologically traumatic events" outside the usual experience of workers in similar roles.
• Whether genuine issues of material fact existed, precluding summary judgment.

Disposition

• The Court of Appeals reversed the summary judgment and remanded the case for trial on the merits (paras 1, 29-30).

Reasons

Per Apodaca CJ (Pickard and Bustamante JJ. concurring):

• The Court interpreted Section 52-1-24(B) to require compensation for primary mental impairment if the worker proves that the mental injury arose from a psychologically traumatic event that is generally outside the usual experience of workers in similar jobs and would evoke significant distress in similar circumstances. The Court held that the statute does not categorically exclude workers in certain occupations, such as paramedics, from compensation (paras 2, 16-23).
• The Court found that the Workers' Compensation Judge erred in concluding that the paramedic's occupation inherently precluded him from meeting the statutory requirements. The determination of whether the events were outside the usual experience of paramedics in Albuquerque is a factual question that must be resolved at trial (paras 24-26).
• The Court also held that there were genuine issues of material fact regarding whether the four events described by the paramedic were "psychologically traumatic events" under the statute. The paramedic's evidence raised reasonable doubt, precluding summary judgment (paras 24-27).
• On the issue of attorney fees, the Court held that the paramedic's entitlement to fees is contingent on his recovery of compensation on remand (para 28).