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A psychiatric unit nurse's psychological injuries allegedly caused by something a speaker said during a training seminar are not compensable, the Tennessee Supreme Court's Special Workers' Compensation Appeals Panel has ruled.
William Ireton, a registered nurse employed by Horizon Mental Health Management L.L.C., oversaw the 10-bed psychiatric unit at Woods Memorial Hospital in Etowah, Tennessee, court records show.
At Horizon's annual conference in September 2012, Mr. Ireton attended a trauma-sensitive care training seminar led by Barbara Lang, senior vice president of clinical practice for the company, according to records. During her presentation, Ms. Lang allegedly told attendees, “I want you to put yourself in your patient's shoes and imagine how it would feel when you're asked, 'Have you ever been physically, emotionally, or sexually abused?'”
As a childhood rape survivor, Mr. Ireton said Ms. Lang's statement caused him to suffer psychological injuries, depression and post-traumatic stress disorder, records show.
Horizon denied Mr. Ireton's claim for workers comp benefits, leading him to file a suit in the Chancery Court for McMinn County, Tennessee, in April 2013, according to records.
He testified that he wasn't trained to “place himself in a patient's shoes,” and that while he routinely asked patients about family trauma, including abuse, details were not discussed, records show.
Ms. Lang denied making the specific statement at the annual conference, but said she's made similar statements, like asking attendees to “imagine a patient entering the psychiatric unit,” according to records.
She testified that she “expects a nurse assessing a patient to align with the patient, to understand the patient, and to develop a therapeutic alliance with the patient in order to make it possible for the nurse to discuss with the patient what is concerning the patient about the admission,” records show.
Following trials in October and November 2014, the Chancery Court for McMinn County decided Mr. Ireton's injuries were not compensable, as the statement that caused his psychological injuries was not “unusual.”
On Tuesday, the Tennessee high court's Special Workers' Compensation Appeals Panel affirmed the trial court's ruling.
Since Ms. Lang's statement was not “abnormal, extraordinary or unusual” compared with the stress experienced by someone working in a psychiatric unit, Mr. Ireton's injuries – “even though they may have resulted from his exposure to that statement” – aren't compensable, the ruling states.