## Facts

- Eugene M. Squeo, age 24, fell from a roof while working for Comfort Control Corp. and suffered a catastrophic spinal-cord injury leaving him a wheelchair-bound quadriplegic.
- A workers’ compensation judge previously adjudicated him totally and permanently disabled and awarded disability payments.
- After prolonged medical complications and repeated hospitalizations, Squeo developed severe depression with suicidal tendencies and attempted suicide multiple times while living in a nursing home.
- Medical testimony attributed his emotional deterioration in significant part to institutional living and supported a treatment goal of maximizing feasible independence in a non-institutional environment.
- Squeo sought an order requiring the employer to fund construction of a self-contained, wheelchair-accessible apartment addition attached to his parents’ home to permit independent living.
- The proposed unit (estimated at more than $65,000) included disability-related features (e.g., barrier-free design and a hydraulic lift) along with ordinary residential components.

## Issues

1. Whether construction of a self-contained apartment addition can qualify as “other treatment” or an “other appliance” under N.J.S.A. 34:15-15 when intended to relieve the effects of a compensable injury, including psychological sequelae.
2. Whether the record contained sufficient credible evidence that the apartment was medically necessary to cure or relieve Squeo’s condition.
3. Whether the employer’s financial obligation could be limited to the reasonable cost of basic independent living quarters, excluding non-necessary amenities.

## Decision

- The New Jersey Supreme Court affirmed the judgment requiring the employer to fund construction of an apartment addition.
- The Court held that, on these facts, the apartment could constitute compensable “other treatment” or an “other appliance” under N.J.S.A. 34:15-15.
- The Court found sufficient credible evidence that the apartment was medically necessary to relieve Squeo’s severe depression and suicidal tendencies by enabling independent living outside an institution.
- The Court upheld limiting employer liability to the components necessary for basic independent living quarters; any “extras” were Squeo’s responsibility.

## Legal Principles

- N.J.S.A. 34:15-15 obligates employers to furnish medical treatment and appliances necessary to “cure and relieve” the worker of the effects of a compensable injury.
- The medical-benefits provision is construed liberally to fulfill the remedial purposes of workers’ compensation, and can include nontraditional measures when medically required to relieve injury-related conditions.
- “Cure and relieve” may include relief of injury-related psychological conditions where supported by competent medical evidence.
- Employer responsibility is bounded by necessity and reasonableness: the benefit must be medically necessary, and the cost must be reasonably related to that therapeutic objective rather than to general lifestyle improvement.

## Conclusion

The court held that an employer may be required under N.J.S.A. 34:15-15 to fund an accessible apartment addition as medical treatment or an appliance when credible medical evidence shows it is necessary to relieve the effects of a compensable injury, including severe psychological harm, and when the employer’s obligation is limited to reasonable costs for basic independent living accommodations.


Squeo v. Comfort Control Corp., 99 N.J. 588, 494 A.2d 313 (N.J. 1985)