## Facts

- Sedonia Sparks worked for Tulane Medical Center and was promoted to manager of the hospital’s distribution center, supervising approximately ten employees.
- Over several years, after attempting to correct workplace misconduct, Sparks experienced repeated harassment and vandalism by co-employees.
- On April 6, 1987, Sparks disciplined or suspended two employees for failing to perform required duties.
- Later that day, Sparks was informed that the disciplined employees had made specific threats against her personal safety.
- Sparks became extremely upset, left work, and soon experienced severe headaches and other symptoms including anxiety, loss of appetite, insomnia, and nightmares.
- Medical and related experts diagnosed her with tension headaches and a job-related psychological disorder and agreed her condition was disabling and caused by work-related stress tied to the April 6 threats in the context of prior harassment.
- Sparks did not work for approximately five months and sought workers’ compensation benefits for that period.
- The trial court found temporary mental disability but denied benefits for lack of an “accident” under La. R.S. 23:1031; the court of appeal reversed and awarded benefits.

## Issues

1. Whether a mental injury induced solely by mental stress, without apparent physical trauma, can qualify as a compensable “personal injury by accident” under La. R.S. 23:1031.
2. Whether the communication of serious workplace threats constituted an “unexpected and sudden employment incident” sufficient to meet the statutory “accident” requirement.

## Decision

- The Louisiana Supreme Court affirmed the judgment awarding Sparks workers’ compensation benefits for a five-month period.
- The court held Sparks proved by a preponderance of the evidence that she suffered a disabling injury caused by an “accident,” defined as an unexpected and sudden employment incident.
- The court concluded that a mental injury induced by mental stress is compensable when caused by a significant, abrupt, and identifiable employment incident, even without apparent physical trauma.
- The district court erred by treating the claim as lacking an “accident” and by viewing the condition as merely general job stress.

## Legal Principles

- Under La. R.S. 23:1031, a compensable “accident” may include an unexpected and sudden employment incident that precipitates disability.
- A mental injury induced by mental stress can be compensable if it is precipitated by a significant, sudden, and identifiable workplace event rather than gradual, ordinary job strain.
- Absence of apparent physical trauma does not bar compensation when competent evidence establishes a disabling mental condition and causation.
- Causation and disability may be proven by a preponderance of the evidence through consistent medical testimony and close temporal connection between the incident and onset of symptoms.

## Conclusion

The court recognized workers’ compensation coverage for a disabling mental condition caused by a sudden, significant workplace incident—here, communicated threats to an employee’s safety—holding that such a mental injury can constitute a compensable “personal injury by accident” even without observable physical trauma.


Sparks v. Tulane Med. Ctr. Hosp. & Clinic, 546 So. 2d 138 (La. 1989)