## Facts

- Vennie M. Watson worked for Melman, Inc. operating a sewing machine.
- A co-employee threw a small spool toward a trash can; it missed and struck Watson behind the ear.
- The physical effects were minor, consisting of slight skin discoloration; medical evidence showed no organic disability.
- After the incident, Watson developed a traumatic neurosis that prevented her from working and was found by the deputy commissioner to be temporarily totally disabling.
- Watson had prior emotional vulnerability, including the earlier death of her teenage son from a blow to the head and significant personal stress.
- The deputy commissioner found the neurosis was causally related to the workplace blow and awarded compensation benefits.
- The full Florida Industrial Commission set aside the deputy’s award and denied the claim, treating the condition as a noncompensable mental or nervous injury “due to fright or excitement only.”
- Watson sought certiorari review of the Commission’s denial.

## Issues

1. Whether a traumatic neurosis is compensable under Florida workers’ compensation law when it follows a workplace accident involving a slight physical impact but no organic disability.
2. Whether the statutory exclusion for mental or nervous injury “due to fright or excitement only” bars compensation when there is some physical injury connected to the mental condition.
3. Whether the Industrial Commission may reject the deputy commissioner’s causation findings where competent evidence supports them.

## Decision

- The District Court of Appeal granted certiorari and quashed the Industrial Commission’s order denying benefits.
- The court held the claimant’s traumatic neurosis was compensable because it was causally related to an actual physical impact at work, even though the physical injury was minimal.
- The court rejected the Commission’s reliance on the “fright or excitement only” exclusion where the record showed a physical blow precipitated the disabling condition.
- The effect of the decision was to reinstate the deputy commissioner’s award of compensation for temporary total disability.

## Legal Principles

- A mental disability such as traumatic neurosis may constitute a compensable workers’ compensation injury when supported by competent evidence and causally connected to a workplace accident involving physical impact.
- The statutory bar for “mental or nervous injury due to fright or excitement only” applies to purely psychic injury without physical injury; it does not apply where physical trauma, even slight, is shown to be the precipitating cause.
- The absence of organic disability does not preclude compensation when medical evidence establishes a disabling psychiatric condition caused by the industrial accident.
- Preexisting emotional susceptibility does not defeat compensability when a work-related accident triggers or aggravates the condition and results in disability.

## Conclusion

The court held that Florida workers’ compensation covers traumatic neurosis when a workplace incident includes some physical impact that causes the condition, and it set aside the Commission’s denial that treated the claim as a noncompensable fright-only injury.


Watson v. Melman, Inc., 106 So. 2d 433 (Fla. Dist. Ct. App. 3d Dist. 1958)