In the case of FAIRFAX COUNTY FIRE AND RESCUE DEPARTMENT, ET AL. v. Randall U. Mottram, the Supreme Court of Virginia, through Justice Cynthia D. Kinser, addressed whether posttraumatic stress disorder (PTSD) qualifies as a disease under workers' compensation law, specifically as an occupational disease per Code § 65.2-400. The court found sufficient evidence to classify Mottram's PTSD as an occupational disease rather than an ordinary disease of life, leading to a partial affirmation and reversal of the Court of Appeals' judgment.
Mottram, employed for 19 years by the Fairfax County Fire and Rescue Department, was diagnosed with PTSD in 1996 following a traumatic emergency response to a fire that resulted in multiple injuries and one fatality. His career included significant exposure to distressing incidents, such as serious accidents and fatalities. Although he transitioned to administrative roles in the early 1990s, he maintained emergency response certification through periodic shifts. The incident on March 10, 1996, where he treated a critically injured child while grappling with the recent death of her stepmother, exacerbated his pre-existing symptoms of anxiety and intrusive thoughts. Following this incident, his mental health significantly deteriorated, culminating in suicidal tendencies and hospitalization by December 1996, where he received intensive treatment, including electroconvulsive therapy.
Dr. Lindahl identified the March 10, 1996 incident as a "critical incident" for Capt. Mottram, who suffers from chronic PTSD. She noted that while this event was significant, Mottram's PTSD was also influenced by other work-related incidents throughout his career with the Fairfax County Fire Department. Dr. Lindahl indicated that there was no evidence of critical incidents outside his employment. During a hearing for his workers' compensation claim, Mottram confirmed he had not experienced medical emergencies or traumatic events outside work.
In 1998, Dr. Lindahl opined that Mottram's PTSD was an occupational disease linked to his long-term exposure to critical incidents in emergency services work. She referenced psychological literature suggesting emergency workers face heightened PTSD risks, with severity increasing over time. Dr. Lindahl pointed to neurochemical changes associated with PTSD, citing research by Southwick et al.
Dr. Randolph A. Frank, a psychiatrist to whom Mottram was referred, agreed with the PTSD diagnosis, noting symptoms including intrusive memories, distressing dreams, anxiety, sleep disturbances, and hypervigilance. In contrast, Dr. Brian Schulman, who evaluated Mottram at the Department's request, diagnosed him with major depression but found no link to his employment-related PTSD symptoms.
Mottram filed a workers' compensation claim in January 1997, asserting an injury from the March incident, which he later withdrew in favor of claiming an occupational disease. The Workers’ Compensation Commission denied his initial claim, stating he had not demonstrated a compensable injury or a causal link to the March incident. Mottram did not appeal this decision but later filed a second application asserting PTSD as an occupational disease. This claim was also denied, as the Commission determined his condition resulted from cumulative trauma rather than distinct traumatic events. The Commission distinguished Mottram’s case from A New Leaf, Inc. v. Webb, concluding his PTSD stemmed from multiple significant incidents rather than a generalized exposure. Mottram subsequently appealed the Commission's decision to the Court of Appeals.
The court reversed a prior decision, classifying Mottram's PTSD as a disease rather than merely an injury by accident. It acknowledged that PTSD can be compensable under certain conditions but determined that Mottram’s condition, linked to neurochemical changes, is analogous to allergic contact dermatitis, suggesting it arises from general life stresses rather than solely occupational stress. The Deputy Commissioner previously found insufficient evidence to classify Mottram’s claim as a compensable ordinary disease of life. The court mandated a remand to the Commission to evaluate if Mottram's PTSD qualifies as such a disease, prompting an appeal from the Employer who disputes the classification of PTSD as compensable. The analysis highlights that the determination of whether an impairment constitutes a compensable disease involves both legal and factual considerations, with the factual aspect—Mottram's PTSD diagnosis—not being contested. The Employer challenges the legal classification of PTSD, arguing it results from multiple traumatic events, categorizing it as a repetitive trauma injury rather than a disease, and notes that PTSD was not included in a legislative amendment that recognized certain conditions as ordinary diseases of life.
The Employer contends that the case of A New Leaf is not applicable because the employee there faced continuous allergen exposure, while Mottram's experiences were distinct traumatic events. Additionally, the Employer points out that Mottram only responded to emergency calls infrequently. However, the ruling in A New Leaf is deemed relevant, as evidence indicated that the employee's contact dermatitis resulted from chemical exposure, which triggered a dermatological reaction distinct from repetitive motion injuries. Similarly, credible evidence supports that Mottram’s repeated exposure to traumatic stressors has affected his neurobiological systems, analogous to the immune response described in A New Leaf. Dr. Lindahl's evidence highlights that severe psychological trauma activates multiple neurobiological systems for survival, which can lead to long-term negative effects associated with chronic PTSD, such as increased anger and impulsivity.
The determination that Mottram’s PTSD qualifies as a disease leads to the next question of its compensability. For PTSD to be compensable, it must meet the criteria of either an occupational disease as per Code § 65.2-400 or an ordinary disease of life treated as occupational under Code § 65.2-401. An occupational disease is defined as one arising out of employment conditions, excluding ordinary diseases of life. Six factors must be established to confirm that a disease is employment-related, including a direct causal connection to work conditions, the natural incidence of work outcomes, and the origin of the disease in employment risks. Conversely, an ordinary disease of life may be treated as occupational if clear evidence shows it arose from employment conditions and is characteristic of the job.
The Employer argues that Mottram's PTSD should not be classified as an occupational disease, asserting that PTSD can arise from traumatic events in everyday life, such as violent assaults or severe accidents. However, only one of the six statutory factors for establishing an occupational disease is relevant in this appeal—specifically, whether Mottram was substantially exposed to PTSD-inducing events outside of his employment, as per Code 65.2-400(B). The Court references prior case law, indicating that determining whether a condition is an ordinary disease of life or an occupational disease is fundamentally a medical issue for the trier of fact.
The focus should be on the nature of Mottram’s occupation and its direct relationship to his PTSD, rather than the various causes of PTSD existing outside of work. Dr. Frank's testimony supports that Mottram's PTSD is closely linked to his service-related activities, and there is no evidence suggesting exposure to traumatic events outside of work. Consequently, the Court concludes that Mottram's PTSD qualifies as an occupational disease under Code 65.2-400.
While acknowledging that PTSD can sometimes be classified as an ordinary disease of life, the specific evidence in this case supports the occupational disease classification. Therefore, the Court affirms part of the Court of Appeals' judgment recognizing Mottram's PTSD as a disease but reverses the portion designating it as an ordinary disease of life. The case is remanded for the calculation of Mottram’s workers’ compensation benefits, affirming in part, reversing in part, and remanding the decision.
