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Appellate Court holds Suicide Triggers Workers' Comp. Benefits (NY)

October 22, 2010

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In the <i>Matter of Smith v. Cornell University</i>, the university appealed a decision of the Workers’ Compensation Board which ruled that the suicide of Smith’s husband was causally related to his employment. Mr. Smith was a painter employed by Cornell when he sustained work-related injuries in 2000 and 2001. Smith’s workers’ compensation claims arising out of a 2001 accident were based on a variety of ailments, including consequential depression. In 2007, Mr. Smith committed suicide and his wife filed a claim for workers’ compensation death benefits, which was approved by the Board.

The Third Department upheld the award finding that death benefits may be awarded for a suicide that “resulted from insanity, brain derangement or a pattern of mental deterioration caused by work-related injury.” The Court found that Mr. Smith had previously alleged depression as an ailment resulting from the accident and his treating psychiatrist confirmed that Smith’s disability and accompanying chronic pain led to his eventual suicide. Although Cornell asserted that other factors contributed to Smith’s suicide, a compensable act need only be a contributing cause of a resulting mental injury.

Thanks to Chris O'Leary for his contribution to this post.
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