Lather v. Huron College

SABERS, Justice

(dissenting).

I dissent.

The majority opinion gives lip service to the accepted proposition that “our worker’s compensation law is remedial in nature and should be liberally construed to effectuate its purpose.” The majority opinion states that “[w]e are mindful of and sensitive to the position that mental illness or disability caused by mental stress is as real as other disabilities and that there is no real distinction between physical and mental injuries especially as it relates to the person injured[,]” yet concludes that “[W]e find nothing in our statutes wherein the legislature has even implied an intention to provide worker’s compensation coverage in these cases.” The majority opinion defies logic, the mandated role of this court as interpreter of this state’s laws, and the caselaw of the majority of other jurisdictions with this feeble attempt to hand to the legislature the work of this court.1

The fact is that the legislature has not, expressly or impliedly, stated an intention to exclude worker’s compensation coverage *376in these cases. On the contrary, it can be argued that by repealing the phrase “by accident” in 1975, the legislature intended to provide worker’s compensation coverage in a less restrictive manner and intended coverage to be extended to these types of cases.

The majority opinion attempts to hide behind the old cliche that “we are not lawmakers nor policy makers.” In this case, we do not have to be. We simply have to serve justice by interpreting the statutory and common law. To do less avoids responsibility. If our interpretation of the law in this case is in error in the eyes of the legislature, the legislature can remedy the situation by new law or policy (clearly expressed).2

The issue is whether mental disabilities produced by work-related stress are com-pensable “injuries” under SDCL 62-1-1(2). Dr. Kennedy testified that the employment at Huron College was a competent-producing cause of the mental condition and the physical injuries subsequently suffered. Accordingly, whether or not “sympathetic to the unfortunate plight of Lather,” we should interpret the law and determine that his injuries are compensable.

A review of caselaw and interpretations of similar compensation statutes shows that the majority of jurisdictions in the United States would find claimant’s injuries compensable.3 Other courts have applied various analytical approaches to the question of compensation for mental disability. The majority opinion, after expending much time and effort in carefully laying out the facts, never addresses any of these approaches. Instead, it cites the Minnesota case of Lockwood v. Independent School Dist. No. 877, 312 N.W.2d 924 (Minn.1981), to support its decision to not decide. The majority, however, fails to note that when the Minnesota court held in 1981 that the legislative intent in amending its worker’s compensation statute could not be determined, that court was discussing an amendment enacted in 1953. This court is being asked to interpret an amendment which was enacted in 1975. While the Minnesota court might be justified in asserting that “it seems unlikely that the legislature contemplated the possibility of such claims when it enacted the 1953 revisionf,]” such an excuse is hardly plausible here. Lockwood, supra at 927. It should also be noted that as of 1984, the Minnesota Supreme Court was still waiting for the legislature to clarify its intent. Egeland v. City of Minneapolis, 344 N.W.2d 597 (Minn.1984).

I would affirm the trial court in holding that Lather’s mental injury and breakdown and the resulting physical injuries are com-pensable injuries under SDCL 62-1-1(2), and that compensation cannot be denied because:

1) some undefinable “average man” might not have reacted the same way, or because
2) the injuries occurred due to an attempted suicide the week after Lather resigned his job, nor because
3) of a claim of “intentional” injury so as to deny coverage under SDCL 62-4-37.

. In light of the nature and purposes of worker’s compensation acts, the recent decisions adopting flexible interpretations of "injuries” represent the better approach. If the purported goal of the statute is to indemnify employees who become disabled from work-related incidents, then the object of inquiry should be the causal relationship between the employment and the disability — not the classification of the injury. Imposing definitional restrictions based on artificial distinctions seriously undermines the achievement of providing support and preventing destitution. Such restrictions deny compensation to disabled workers merely because they did not happen to become injured in the proper way.

Unless the South Dakota Supreme Court follows the Minnesota example of refusing to construe the meaning of "injury” in favor of deferring the matter to the Legislature, the court will ultimately be forced to address the issue. Deferring the question might be defensible because of the policy considerations involved, however this course of action is less than exemplary. Declining to construe the term "injury" would represent circumvention of a judicial issue through the convenience of subject matter relegation. Such deferral directly conflicts with the judiciary’s vested duty to construe statutes and resolve questions of law. This obligation is not suspended merely because of the existence of novel facts or policy considerations. Because worker's compensation laws are "remedial in character and are entitled to a liberal construction,” the South Dakota Supreme Court should determine that employees who are disabled by mental stimuli are entitled to compensation. In the absence of legislative mandate to the contrary, the ideals and policies of worker’s compensation dictate that employees disabled from all work-related incidents should be entitled to relief.

Mental Disorders and Suicide as Compensable Injuries Under Worker’s Compensation: Will South Dakota Follow the Trend? 30 S.D.L.Rev. 636, 641-42 (1985).

. The subject matter of the footnote on page 8 is not only “not relevant" but is received in clear violation of the “collateral source rule.” Travelers Insurance v. Manning, 574 S.W.2d 237 (Tex.Civ.App.1978); Twin City Fire Ins. Co. v. Gibson, 488 S.W.2d 565 (Tex.Civ.App.1972); Eichel v. New York Central Railroad Co., 375 U.S. 253, 84 S.Ct. 316, 11 L.Ed.2d 307 (1963).

. See generally, 1A Larson, The Law of Workmen’s Compensation § 36.00 (1985); 1B Larson, The Law of Workmen’s Compensation § 42.00 et seq. (1987); S. Sersland, Mental Disability Caused by Mental Stress: Standards of Proof in Workers’ Compensation Cases, 33 Drake L.Rev. 751,760 n. 44 (1983-1984). Comment, Workers’ Compensation and Gradual Stress in the Workplace, 133 Univ. of Pa.L.Rev. 847,850 n. 6, 851 n. 11 (1985).