## Facts

- Rosalie Kahle worked for Plochman, Inc. at a mustard-packing plant in Vineland, New Jersey.
- In 1966, she suffered a serious workplace accident when a skid fell on her back, causing major back and leg injuries.
- She underwent extensive treatment, including hospitalization, lumbar disc removal, spinal fusion, and long-term medication for pain and depression.
- In 1971, she received a workers’ compensation award for 66 2/3% permanent partial disability, including orthopedic, neurological, and psychiatric consequences.
- She never returned to work and experienced continuing pain, repeated hospitalizations, and diagnoses including severe arachnoiditis and related complications.
- A dorsal column stimulator was implanted in 1973 but failed to relieve her pain.
- Roughly ten years after the accident, she died by suicide, leaving notes describing inability to endure pain, anxiety, and depression; expert testimony linked the suicide to the work injury.

## Issues

1. Whether N.J.S.A. 34:15-7 bars dependency death benefits when an employee’s suicide is allegedly caused by a work-related injury that produced severe mental disturbance.
2. Whether New Jersey should retain a restrictive rule requiring lack of conscious intent or understanding to avoid the “intentionally self-inflicted” exclusion.

## Decision

- The New Jersey Supreme Court reversed the dismissal of the dependency claim and remanded for further proceedings.
- The court held that suicide is not “intentionally self-inflicted” under N.J.S.A. 34:15-7 when work-related injuries cause a mental disturbance so severe that the suicide is not the product of a true freedom of choice, even if the act appears volitional.
- The court replaced the prior restrictive approach with a standard centered on causation and the severity of the work-caused mental disturbance.
- On remand, the compensation judge was directed to apply the new standard to the medical and psychiatric evidence to decide compensability.

## Legal Principles

- Workers’ compensation exclusions for “intentionally self-inflicted” injury or death do not apply where a work-related injury produces a mental disturbance that overwhelms normal rational judgment and directly causes suicide.
- The compensability inquiry requires a causal chain: (1) compensable work injury; (2) resulting mental disturbance of sufficient severity to override rational judgment; and (3) suicide as a direct consequence of that disturbance.
- The remedial purpose of the Workers’ Compensation Act supports liberal construction in favor of coverage when consistent with statutory intent, including recognition of severe pain and depression as potential causal forces affecting intentionality.
- Proof remains necessary; the claimant must establish the required causal nexus and the severity of mental impairment under the announced standard.

## Conclusion

The court held that a work-related injury leading to a severe mental disturbance that overrode rational judgment can render a later suicide compensable, because such a death is not “intentionally self-inflicted” within the statutory bar; the dependency claim was reinstated for determination under the new test.


Kahle v. Plochman, Inc., 85 N.J. 539, 428 A.2d 913 (N.J. 1981)