## Facts

- Diana Wolfe worked for a department store, first as an investigator and later as secretary to the security director, John Gorman.
- Gorman experienced increasing workplace stress and escalating agitation and nervousness; Wolfe became closely involved in assisting him and taking on some of his duties.
- Gorman’s mental condition deteriorated despite a doctor visit suggested by Wolfe.
- At work, Gorman summoned Wolfe by intercom and asked her to call the police to a specific room; when she could not reach him again, she went to his office and found him dead from a self-inflicted gunshot wound.
- Wolfe developed severe psychological symptoms; a psychiatrist diagnosed an acute depressive reaction.
- Wolfe was hospitalized for extended periods, including treatment with electroshock, and was unable to work during the claimed disability period.
- A workers’ compensation referee awarded benefits; the Workmen’s Compensation Board affirmed as a compensable accidental injury.
- The Appellate Division reversed and dismissed, applying a rule that mental injury caused solely by mental stimulus was not compensable.

## Issues

1. Whether a disabling psychological injury caused by work-related psychic trauma, without physical impact, can qualify as an “accidental injury” under the New York Workmen’s Compensation Law.
2. Whether the Appellate Division could dismiss the claim based on a categorical bar to “mental-mental” claims despite the Board’s supported findings of causation and disability.

## Decision

- The Court of Appeals reversed the Appellate Division and reinstated the Workmen’s Compensation Board’s award.
- The court held that psychological or nervous injury precipitated by psychic trauma may be compensable to the same extent as physical injury.
- The court rejected a physical-impact requirement and declined to apply a categorical rule barring compensation for mental injury caused solely by mental stimulus.
- The court treated the supervisor’s suicide and Wolfe’s discovery of the body as a sudden, unexpected, and shocking work-related event capable of constituting an “accident.”
- The court relied on the uncontroverted record and medical evidence supporting a direct causal connection between the workplace event and Wolfe’s disabling depression.

## Legal Principles

- An “accidental injury” under the Workmen’s Compensation Law may include disabling mental injury caused by work-related psychic trauma, even without bodily impact.
- The absence of physical impact does not defeat compensability where a claimant proves a work-related accidental event and medical causation.
- Workers’ compensation statutes are remedial and should be construed to cover injuries within their purpose rather than limited by extra-statutory categorical exclusions.
- Appellate courts should not impose a per se legal bar that overrides the Board’s supported findings on causation and disability in a particular case.

## Conclusion

The court recognized that severe depression triggered by a shocking workplace घटना may constitute a compensable accidental injury, and it reinstated benefits where the record established work-related psychic trauma and medical causation despite the lack of physical impact.


Matter of Wolfe v. Sibley, Lindsay & Curr Co., 36 N.Y.2d 505 (N.Y. 1975)