## Facts

- James Richard Fenwick worked as a psychological assistant at the Oklahoma State Penitentiary.
- During a prison hostage crisis on August 8, 1979, Fenwick negotiated for three hostages’ release by substituting himself; he was held for about four and one-half hours and released without physical injury.
- Fenwick returned to work after two days and stayed in the position until resigning on October 1, 1982, for similar employment elsewhere.
- Fenwick filed a workers’ compensation claim seeking disability benefits; the carrier paid for medical and psychiatric treatment for several years.
- Physicians diagnosed Fenwick with psychiatric disorders, including post-traumatic stress disorder and related anxiety/depression conditions.
- Fenwick reported physical complaints (e.g., shakiness, headaches, tingling, stomach discomfort), but the medical evidence did not identify a separate physical injury.

## Issues

1. Whether psychiatric disability caused by mental stress from a single, work-related traumatic incident, without accompanying physical injury, constitutes a compensable “accidental personal injury” under the Oklahoma Workers’ Compensation Act.

## Decision

- The Oklahoma Supreme Court granted certiorari after the Court of Appeals reversed the Workers’ Compensation Court.
- The Supreme Court vacated the Court of Appeals’ opinion.
- The Supreme Court sustained the Workers’ Compensation Court’s order denying benefits.
- The court held that, under Oklahoma law, physical injury must be present for disability to be compensable; Fenwick’s purely mental injury claim was not compensable.

## Legal Principles

- Under the Oklahoma Workers’ Compensation Act as construed by the court, a disease or disorder of the mind or body arising in the course of employment, “with nothing more,” is not an accidental injury and is not compensable.
- Physical injury is required for a disability to be compensable; mental stress alone, even if triggered by a definite, identifiable work incident, does not satisfy the “accidental personal injury” requirement.
- Physical sensations or complaints that are manifestations of mental stress do not, without evidence of actual physical injury, transform a mental injury into a compensable claim.

## Conclusion

The court denied workers’ compensation benefits because Fenwick’s psychiatric conditions, though work-related and tied to a discrete traumatic event, were not accompanied by a physical injury as required for compensability under Oklahoma’s interpretation of “accidental personal injury.”


Fenwick v. Okla. State Penitentiary, 792 P.2d 60 (Okla. 1990)