Personal Reaction Test Could Not Be Used to Assess Injury from Emotionally Traumatic Workplace Event

An employee allegedly developed severe depression resulting from employer-initiated vocational rehabilitation after a work-related injury prevented the employee’s return to his prior work. The court held that it was error to assess the employee’s claim based on a “personal reaction test” i.e. whether the traumatic event could have caused a similar injury in an ordinary employee not predisposed to this injury by a mental disorder. Rather, the employee must show: (1) an actual psychological injury; and (2) whether the alleged stressors were in reality part of the work place environment, as opposed to fabrications or imaginings of the employee.


A test for the existence of actual workplace stressors must be one verifying the factual reality of stressors in the workplace environment, rather than one requiring the claimant to prove that a hypothetical average or healthy person would have suffered a similar psychological injury. The court found the “mental-mental” workers compensation claim could be defined as one in which an employee allegedly suffers from a mental injury caused by an emotionally traumatic workplace event or stressor. See: Muhammad v. District of Columbia Dept. of Employment Services, 2012 WL 18622 (D.C. Jan 05, 2012) (not designated for publication).