## Facts

- Beulah Seitz worked as a secretary and helped supervise a rapid relocation of her employer’s operations from Worcester, Massachusetts, to Smithfield, Rhode Island.
- After the move, the new facility was highly disorganized: records were missing, phones malfunctioned, portions of the premises were occupied by prior tenants, and coworkers were inexperienced.
- Seitz performed duties beyond her secretarial role, including cleaning and protecting equipment from water due to a leaking roof.
- After about sixteen working days (Sept. 15–Oct. 3, 1975), Seitz left work and claimed total disability based on a psychological condition.
- A psychiatrist diagnosed Seitz with an obsessive-compulsive personality disorder that preexisted the employment and opined that the stressful working conditions aggravated that condition and caused disabling emotional trauma, without any physical injury.
- The workers’ compensation commission awarded total disability benefits; the appellate commission affirmed; the employer appealed.

## Issues

1. Whether a purely psychological injury, without physical trauma, can qualify as a compensable “personal injury” under the Workers’ Compensation Act.
2. Whether work-related aggravation of a preexisting psychological disorder can be compensable.
3. Whether competent evidence supported the commission’s finding that employment conditions caused or contributed to Seitz’s disabling psychological condition.

## Decision

- The Rhode Island Supreme Court affirmed the decree awarding total disability benefits.
- The court held that a psychological or emotional injury can constitute a compensable personal injury even without physical trauma, if it arises out of and in the course of employment.
- The court held that aggravation of a preexisting psychological condition is compensable when employment is a contributing cause of the resulting disability.
- The court found sufficient competent evidence—particularly medical testimony and evidence of workplace stressors—to support causation and declined to reweigh the commission’s factual findings.

## Legal Principles

- “Personal injury” under the Workers’ Compensation Act may include purely psychological harm; the statute does not require a physical precipitating event.
- An employer takes the employee as found; if employment activates, accelerates, or aggravates a preexisting condition (including psychological), resulting disability is compensable.
- Causation is satisfied where employment is a contributing cause of the psychological injury or aggravation, supported by competent medical evidence.
- On appellate review, the court upholds workers’ compensation findings if supported by any competent legal evidence.

## Conclusion

The court sustained an award of total disability benefits where severe workplace stress and disorganization aggravated an employee’s preexisting psychological disorder, confirming that work-caused mental injuries may be compensable even absent physical trauma when supported by competent evidence and causal connection findings.


Seitz v. L & R Indus., Inc., 437 A.2d 1345 (R.I. 1981)