## Facts

- Robert Lee Candelaria worked for General Electric Company (GE) and had a long, steady work history before the events at issue.
- Before joining GE, Candelaria served in the military and was honorably discharged without reported psychological problems.
- After military service, Candelaria advanced at another employer from plater to foreman to plant manager; after that business closed, he worked for other employers without incident.
- At GE, Candelaria worked successfully in multiple roles (including janitor, forklift operator, and preparing parts for plating) and worked under several supervisors without problems.
- Candelaria’s difficulties began when he started working for a supervisor, Jewett, who had a reputation as a difficult supervisor.
- After another employee quit, Jewett assigned Candelaria additional duties from the vacant position while still expecting Candelaria to meet the same timing requirements for his original work.
- Candelaria repeatedly asked Jewett and other plant management for help or staffing relief, but GE did not assign another employee to assist him.
- During a workday when Jewett stood over Candelaria giving orders, Candelaria began shaking and felt as though he was going to kill Jewett; he did not act on the impulse.
- Candelaria was hospitalized multiple times for psychological problems. He returned to work between hospitalizations, and renewed pressure from Jewett was followed by renewed flare-ups.
- A treating doctor testified that Candelaria had no condition that would cause him to misperceive reality, supporting that his response was to actual workplace conditions rather than delusions.
- Candelaria filed a workers’ compensation claim. The trial court found his disabling psychological injury arose out of and in the course of employment due to actual job stress and awarded benefits.
- GE appealed.

## Issues

1. Whether a disabling psychological injury that developed from continuing workplace stress, without physical trauma or a single sudden event, can qualify as a compensable “accidental injury” under New Mexico workers’ compensation law.
2. Whether substantial evidence supported the trial court’s finding that Candelaria’s disability was caused by “actual” job stress arising from workplace conditions, rather than by a subjective distortion of reality unrelated to the job.

## Decision

- Affirmed.
- The court held that a disabling psychological condition may constitute a compensable accidental injury when it is caused by actual job stress arising out of and in the course of employment, even if the condition develops gradually and is not accompanied by physical trauma.
- The court rejected GE’s argument that the injury was noncompensable merely because it was gradual rather than tied to a single discrete accident.
- The court also concluded there was substantial evidence that the stressors were real workplace conditions and that those conditions caused the disability, including evidence of the increased workload, management’s refusal to provide help, the temporal link between supervisory pressure and symptom flare-ups, and medical testimony that Candelaria was not misperceiving reality.

## Legal Principles

- A compensable “accidental injury” under New Mexico workers’ compensation law can include a purely psychological injury resulting in disability; physical trauma is not required.
- A psychological injury may be “accidental” even when it arises over time from continuing conditions of employment, so long as the resulting disability is unexpected and causally connected to the job.
- Compensability requires proof that the psychological disability arose out of and in the course of employment and was caused by actual job stressors, not by imagined events or a distortion of reality unrelated to work conditions.
- Appellate review of workers’ compensation fact-finding is for substantial evidence; the reviewing court does not reweigh evidence when the record supports the trial court’s findings.

## Conclusion

Candelaria held that New Mexico workers’ compensation may cover a disabling psychological breakdown without physical trauma when the worker proves the disability arose out of and in the course of employment and was caused by actual workplace stress, and the Court of Appeals affirmed the trial court’s award because substantial evidence supported causation and the existence of real job-related stressors.


Candelaria v. General Electric Company, 730 P.2d 470, 105 N.M. 167 (1986)