Can Teaching 6th Graders Cause Compensable Anxiety Disorder?

Sheila Chavis

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This past March (3/6/07) the North Carolina Court of Appeals addressed the issue of whether a 6th grade teacher's physician-diagnosed anxiety disorder was compensable under North Carolina's Workers' Compensation Act.

After a review of the facts found by the Industrial Commission the Court concluded that teaching sixth graders did not expose the teacher to any stressors that were not experienced by the general public. Instead the Court concluded that the teacher created the stressful environment herself through poor performance as a teacher. In pertinent part, the Court wrote:

Plaintiff has the burden of showing that her anxiety disorder arose due to stresses and conditions unique to her employment. Pitillo, 151 N.C. App. at 648, 566 S.E.2d at 813. Here, the Commission found, and there was substantial evidence to show, that under the circumstances presented in this case, plaintiff's anxiety disorder did not develop from "causes and conditions which are characteristic of and peculiar to a particular trade, occupation or employment[.]" N.C. Gen. Stat. § 97-53(13). Plaintiff's employment as a sixth-grade teacher did not expose her to unusual and stressful conditions, nor did defendant require her to perform any extraordinary tasks. While we acknowledge the challenges and stress teachers encounter every day in their classrooms, we cannot conclude under the facts of this case that plaintiff faced challenges and situations unlike those confronting the general public, including other teachers. Compare Smith-Price, 160 N.C. App. at 171, 584 S.E.2d at 888 (affirming the Commission's finding that the claimant's job exposed her to unique stress not experienced by the general public where the claimant was a nurse working with severely mentally ill and often suicidal patients, including minor patients, and where treatment errors could and had resulted in a minor patient's death, whose death the claimant took very personally). Plaintiff asserts she was "subjected" to a dangerous and volatile work environment, but the evidence tends to establish that plaintiff herself created the stressful work environment through her inability to perform the ordinary tasks expected of her and every other teacher. Because plaintiff failed to show that her employment placed her at an increased risk of developing an occupational disease, the Commission properly denied workers' compensation benefits.

For more information on this subject, please refer to our section on Workplace Injuries and Discrimination.