SW Legal Educational Publishing

Depression from Being Disciplined at Work
Eligible for Workers’ Compensation
Description Teacher was disciplined by her school principal for having struck a child. The conflict over the incident caused her to become depressed and unable to work. Hawai’i Supreme Court holds that since the depression arose over a work incident, the teacher may collect workers’ compensation. (Updated 10-3-97)
Topic Employment Law
Key Words Workers’s Compensation, Stress
C A S E   S U M M A R Y
Facts Mitchell was a sixth-grade teacher. Rules prohibited corporal punishment or the use of rewards to motivate students. Mitchell would let her class have parties and play Nintendo on Friday if they had been good. She had several conflicts during her first months at the school with the principal because of these rewards. Mitchell said the confrontations caused her to develop “flu-like” symptoms. Later, Mitchell learned that a student had stolen party cookies. When she confronted him, he began yelling and throwing papers from her desk. Mitchell said that in trying to grab the papers she accidentally bumped him with her forearm; he said she hit him. The principal determined Mitchell had hit the student and suspended her for five days. After she returned, Mitchell became depressed, experiencing fatigue, confusion, insomnia, fever, and loss of appetite. She quit reporting to work and filed for workers’ compensation. The Labor and Industrial Relations Appeals Board denied Mitchell’s claim, holding that her "reactive depression" resulting from the disciplinary action she suffered for violating school policy was personal and outside the scope of employment. Mitchell appealed.
Decision Vacated and remanded. Workers’ compensation laws should be liberally construed regardless of questions of negligence and proximate cause, because "work injuries are among the costs of production which industry is required to bear." Even if Mitchell did hit the student in violation of school policy, that, and the discipline that followed from it, were in the course of employment. Her depression arose out of this employment incident, so she is due compensation.
Citation Mitchell v. Hawai’i, Slip Copy (1997 WL 378685, Sup.Ct., Haw.)
or
942 P.2d 514 (Sup. Ct., Haw., 1997)

Back to Employment Law Listing

©1997  South-Western, All Rights Reserved