## Facts

- Vincent Moore was an elementary school teacher employed by the Chicago Board of Education (BOE) for many years.
- Over several school years, Moore experienced multiple stressful work incidents, including assaults, injuries, and robberies, some involving students.
- Moore also had extensive job paperwork and related tasks that typically required several hours of work after the regular school day.
- Near the end of the summer break before what would have been Moore’s twelfth year of teaching, he took a leave of absence to obtain counseling and treatment for mental illness.
- After the leave, the BOE denied Moore’s request to return to work because he did not pass the BOE’s psychiatric evaluation.
- Moore pursued benefits under Illinois’s Workers’ Occupational Diseases Act (ODA), asserting that his psychiatric condition developed gradually from the compounding stressors of his teaching job.
- At arbitration, Moore presented testimony from psychiatric social worker Deborah Gessner, who opined that Moore’s mental illness was caused by his employment conditions.
- Moore acknowledged a strained family situation and a history of psychiatric issues.
- An arbitrator awarded ODA benefits; the Industrial Commission affirmed; the circuit court confirmed; and the BOE appealed.

## Issues

1. Whether a psychiatric illness allegedly caused by cumulative work stress and recurring workplace incidents, without a single identifiable traumatic event, qualifies as a compensable “occupational disease” under the ODA.
2. Whether Moore proved that his employment exposed him to a risk of mental illness greater than that faced by the general public and arising from conditions peculiar to his work, as required by the ODA.
3. Whether the Commission’s award could stand when the claimed condition arose from workplace conditions the court viewed as shared by other employees in similar jobs.

## Decision

- The Industrial Commission affirmed the arbitrator’s award of ODA benefits, and the circuit court confirmed the Commission’s decision.
- The Illinois Appellate Court, First District, Industrial Commission Division, reversed.
- The appellate court set aside the award, concluding that Moore’s mental illness, attributed to cumulative job stress and conditions common to the workplace, did not meet the ODA’s legal requirements for a compensable occupational disease.

## Legal Principles

- Under the ODA, a compensable occupational disease must arise out of and in the course of employment and result from employment conditions that are characteristic of and peculiar to the work, exposing the employee to a greater risk than the general public.
- A purely psychological injury may be compensable in limited circumstances, such as when it is traceable to a sudden, severe emotional shock connected to a definite time, place, and cause (as recognized in prior Illinois authority).
- The ODA does not provide compensation for a mental disorder attributed to job-induced stress, anxiety, or depression arising from workplace conditions to which employees are generally subject, absent a qualifying extraordinary event or a distinctly job-specific hazard meeting the Act’s “greater risk/peculiar to employment” requirements.
- Even when the Commission accepts medical testimony linking symptoms to work, a benefits award cannot stand if the claimant’s proof does not satisfy the ODA’s statutory standard for an occupational disease.

## Conclusion

The appellate court reversed the circuit court and set aside the Commission’s award, holding that Moore’s psychiatric illness—attributed to the accumulation of stressful teaching conditions, paperwork burdens, and repeated school incidents—was not a compensable occupational disease under the ODA because it stemmed from conditions the court treated as part of the workplace environment faced by similarly situated employees rather than a qualifying sudden traumatic shock or a risk peculiar to the employment and greater than that faced by the general public.


Chicago Board of Education v. Industrial Commission, 523 N.E.2d 912 (1988)