Texas Employers' Insurance Ass'n v. Saunders

COULSON, Justice

(concurring).

I concur that this case is controlled by the decision of the Supreme Court in Jones v. Traders & General Ins. Co., 140 Tex. 599, 169 S.W.2d 160 (Tex.Sup.1943). However, the rule stated in that case should be reviewed at this time in light of the present state of scientific knowledge of medications and their effects upon human behavior.

In the case before this Court, the evidence establishes that the deceased employee, Saunders, as a result of his work related injury, was subjected to back surgery. He had thrombophelibitis and chronic and severe pain which required his physicians to simultaneously prescribe four different drugs in order to afford him a degree of relief from his torment. At and before his death, Saunders was under the influence of such prescribed drugs which, when combined, induced mental depression and altered his normal mental processes in a manner which impaired his normal good judgment. The combination of the pain resulting from his injury, together with the prescribed medication, so impaired his thought processes that he did a tragic thing in taking his life. The evidence would justify a conclusion that Saunders would not have committed that final act but for the injury suffered in the course of his employment, the consequential pain and suffering, and the medical treatment made necessary as a result of such injury.

Since the Jones decision, medical science has made significant progress in knowledge relating to psychotropic drugs and their effect upon behavior. It is now known that use of such drugs can alter normal patterns of human thought, reasoning, and behavior.

*246Mr. Saunders is dead. A proximate cause of his death was the chain of events initiated by the injury which he suffered while in the course' of his employment. The Workmen’s Compensation Act was intended to compensate the dependent survivors of a workman who died as a result of job related injuries.

It should not be necessary for the dependent survivors of a deceased employee to meet a burden of proof on the issue of insanity more onerous than that required by Texas courts in criminal cases where insanity is raised as a defense. 16 Tex. Jur.2d Criminal Law § 93 (1960).

The act of Mr. Saunders in taking his life should be judged in the light of medical testimony to the effect that he could not bring his conduct within the standards normally applied when evaluating human behavior because of the effect of the injury and the medications which were prescribed to treat that injury.