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Deputy sheriff not entitled to comp after PTSD diagnosis ended

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PTSD

The Minnesota Supreme Court ruled a deputy sheriff receiving workers compensation benefits after being diagnosed with post-traumatic stress disorder was not entitled to continue receiving benefits after his diagnosis changed.

The state high court on Wednesday agreed with the Workers’ Compensation Court of Appeals, which reversed a compensation judge’s decision allowing the deputy to continue receiving benefits after the diagnosis change.

The deputy, employed by Mower County from November 2007 to March 2020, argued he should have been entitled to continued comp benefits because he remains disabled from a mental illness.

A doctor had reevaluated the deputy, determining he no longer met the criteria for PTSD.

The deputy argued that even though he no longer had diagnosed PTSD, he still experienced disablement and should be entitled to benefits.  

The compensation judge found the deputy to be temporarily totally disabled and awarded him benefits from April 1, 2020, to the present. The Workers’ Compensation Court of Appeals reversed the order, determining the deputy’s occupational disease was resolved, making him ineligible for continued benefits.

The state Supreme Court said an employer’s liability for comp benefits ends when a worker is no longer disabled by a work-related injury, and that in this case the deputy was no longer disabled for the purposes of comp after a doctor said he no longer suffered from PTSD.

The court ruled that while it is sensitive to the “well-being of Minnesota workers experiencing mental illness,” it is up to the legislature to change the law concerning who may be entitled to comp benefits and under what circumstances.

In Minnesota, the court noted, the only mental impairment to qualify for workers comp is PTSD, and other disabling mental impairments are specifically excluded from comp coverage.